• Qualified beneficiaries (not just covered employees);
• Who experienced a qualifying event at any time from September 1, 2008 through December 31, 2009 (regardless of the type of qualifying event); and
• Who either:
  • Have not yet been provided an election notice; or
  • Who were provided an election notice on or after February 17, 2009 that did not include the additional information required by ARRA.

An abbreviated version of the general notice, which includes the same information as the full version regarding the availability of the premium reduction and other rights under ARRA, but does not include the COBRA coverage election information, may be sent in lieu of the full version to individuals who meet all of the following criteria:

• Have experienced a qualifying event on or after September 1, 2008;
• Have already elected COBRA coverage; and
• Currently have COBRA coverage.

Note: Individuals who experienced a qualifying event (that was a termination of employment) in December 2009 but who were not eligible for COBRA coverage until January 2010 were likely not provided proper notice. These individuals should get the updated General Notice AND the full 60 days from the date the updated notice is provided to make a COBRA election.

The Premium Assistance Extension Notice: Plan administrators must also provide notice to certain individuals who have already been provided a COBRA election notice that did not include information regarding ARRA, as amended. The DOL has developed a model Premium Assistance Extension Notice. This notice includes information about the changes made to the premium reduction provisions of ARRA by the 2010 DOD Act. Listed below are the affected individuals and the associated timing requirements.

• Individuals who were "assistance eligible individuals" as of October 31, 2009 (unless they are in a transition period - see below) and individuals who experienced a termination of employment on or after October 31, 2009 and lost health coverage (unless they were already provided a timely, updated General Notice) must be provided notice of the changes made to the premium reduction provisions of ARRA by the 2010 DOD Act by February 17, 2010. 
• Individuals who are in a "transition period" must be provided notice of the changes made to the premium reduction provisions of ARRA by the 2010 DOD Act within 60 days of the first day of the transition period. (The transition period begins immediately after the end of the nine months of premium reduction in effect under ARRA before the amendments made by the 2010 DOD Act, as long as the premium reduction provisions of the 2010 DOD Act would apply due to the extension from nine to 15 months).

Note: Some individuals may be entitled to multiple notices. To satisfy the notice requirements, these individuals may be provided a single notice that includes all of the required information so long as the notice is provided by the earliest date required.

Unless specifically modified by ARRA, the existing COBRA notice manner and timing requirements continue to apply.

The notices must include the following information:

• The forms necessary for establishing eligibility for the premium reduction;
• Contact information for the plan administrator or other person maintaining relevant information in connection with the premium reduction;
• A description of the second election period (if applicable to the individual);
• A description of the requirement that the Assistance Eligible Individual notify the plan when he/she becomes eligible for coverage under another group health plan or Medicare and the penalty for failing to do so;
• A description of the right to receive the premium reduction and the conditions for entitlement; and
• If offered by the employer, a description of the option to enroll in a different coverage option available under the plan.

The DOL created model notices to help plans and individuals comply with these requirements. Each model notice is designed for a particular group of qualified beneficiaries and contains information to help satisfy ARRA's notice provisions, including those added by the 2010 DOD Act. These updated notices can be found at www.dol.gov/ebsa/COBRAmodelnotice.html.

Health Update
 

 

Have a nice drive!

Air pollution from car fumes is the likely culprit, suggest Annette Peters, PhD, and colleagues at the Institute of Epidemiology, Helmholtz Center, Munich, Germany.

In a previous study, Peters and colleagues found that a sizeable proportion of heart attacks - about 8% - could be attributed to being in traffic.

To follow up, the researchers interviewed 1,454 people who survived heart attacks. In the hour before their heart attack, many of the survivors had been in heavy traffic.

Analysis of the data showed that these heart-attack-vulnerable people were 3.2 times more likely to suffer a heart attack if they'd been in heavy traffic in the previous hour.

"One potential factor could be the exhaust and air pollution coming from other cars," Peters says in a news release. "But we can't exclude the synergy between stress and air pollution that could tip the balance."

Making it less likely that stress was involved was the fact that patients didn't have to be driving; the risk was the same whether they were driving or taking the bus.

Traffic appeared to be five times more dangerous to women than to men in the study, although the relatively small number of women in the study (325) may have made this calculation less accurate.

To nail down the true culprit, Peters and colleagues are working with University of Rochester researchers to determine exactly what it is about traffic that raises heart attack risk.

In that study, 120 healthy volunteers are driving to work and running errands wearing heart monitors, while other instruments measure their exposure to air pollution and to noise. The data and findings from this trial are not yet available.

 

 

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