Model COBRA Subsidy Extension Notices Released By The DOL
|
|
The Department of Labor (DOL) has released the following three model notices addressing the extension of the COBRA premium subsidy under the Department of Defense Appropriations Act (DOD Act) that was enacted at the end of 2009:
Updated Model General Notice: Plans subject to the Federal COBRA provisions must provide this updated model general notice to all qualified beneficiaries (not just covered employees) who experienced a qualifying event at any time from September 1, 2008 through February 28, 2010, regardless of the type of qualifying event, and to those who have not yet been provided an election notice. Individuals who experience any qualifying event after December 19, 2009 must get the updated model general notice within the normal timeframes for providing a COBRA election notice.
Premium Assistance Extension Notice: Plan administrators must provide notice to certain individuals who have already been provided a COBRA election notice that did not include information regarding ARRA, as amended. This model 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).
Updated Alternative Notice: Insurance issuers that provide group health insurance coverage must provide notice to persons who became eligible for continuation coverage under a State law. This updated model notice will assist issuers with satisfying this requirement. However, continuation coverage requirements vary among States and issuers should modify this model notice as necessary to conform it to the applicable State law.
Sullivan Benefits clients receive COBRA administration services at no additional cost. Whether you currently utilize this service or not, the Sullivan Benefits team is available to assist you in understanding and implementing these new provisions.
As always, please contact us with any questions or assistance in complying with the new COBRA regulations. |
|
Needham Heights Office:
72 River Park · Needham Heights, MA 02494-2631
Phone: 781.449.8323 · Fax: 781.449.5419
Worcester Office:
One Chestnut Place · Worcester, MA 01608-2804
Phone: 508.471.9017 · Fax: 508.797.3689
|
