California-COBRA and Federal COBRA Guidelines
Good afternoon,
You may have more questions regarding dental coverage and other issues affected by the American Recovery and Reinvestment ACT (ARRA).
First, the dental insurance premium is NOT a subsidized premium. March 1, 2009 is a new and, in some cases, a former employee's second opportunity for election, under California-COBRA and Federal COBRA guidelines, for continuation of coverage for the former employee and/or their dependents' health, dental, vision, counseling, flexible spending arrangements (FSA), as well as a health reimbursement arrangement that qualifies as a FSA and an on-site medical clinic.
Per California-COBRA and Federal COBRA election rules, a former employee has 60 days, starting March 1, 2009, to respond, in writing, to an election. After that, the former employee has a maximum of 45 days from the date they submitted, in writing, a request for the continuation of benefits for themselves and/or dependent(s) to pay the premium - 35% of their health insurance coverage. (102% of the gross monthly premium for all other insurance benefits. California COBRA allows an insurance carrier to charge up to 110% of the gross monthly premium for all other insurance benefits.)
Please be aware that while March 1, 2009 begins the new election period, the 18-month count (the period of time allowed under Federal COBRA; California COBRA-stand alone is 18 months - applies to employers who have 2 - 20 employees on a full-time basis. California-COBRA can be added to Federal COBRA), except in the case of a former employee becoming disabled or the death of a former employee; these events may allow coverage for dependents for an additional number of months, begins on the first of the month after an employee was terminated - regardless of whether the termination was voluntary or involuntary.
In order to qualify for the "special election period under the ARRA of 2009," the former employee's date of termination must fall on or after September 1, 2008.
If this information is still clear as mud, feel free to call, email or fax. We're always available to answer your questions and help you sort out this complicated legislation for your company and staff.
Best,
Ken Robbins and Staff