COBRA Compliance Alert #13
Department of Labor’s Employee Benefits Security Administration Has Posted New Guidance on Maintaining Coverage after Expiration of COBRA Premium Subsidy Period on Their Dedicated COBRA Webpage:
- Qualifying Event eligibility range for ARRA Subsidy remains September 1, 2008 to May 31, 2010
- The Unemployment Compensation Extension Act of 2010, signed by the President on July 22, 2010, did not extend the COBRA premium reduction.
- Note: only those whose qualifying event occurred on or before May 31, 2010 are eligible for the ARRA Subsidy and may continue to receive the premium assistance for up to 15 months, depending upon their eligibility for other group health plans or Medicare.
- The DOL’s fact sheet contains tips for affected individuals, including a warning that plans are not required to remind affected individuals that the subsidy period is ending.
- The guidance emphasizes the importance of paying the remaining months of COBRA at full price because some health coverage rights or options are lost if COBRA is terminated for nonpayment.
- For individuals who do lose COBRA coverage due to nonpayment, the DOL provides suggestions about other possible coverage options.
Fact Sheet: http://www.dol.gov/ebsa/cobra.html
As always, we will be keeping our clients informed of all regulatory changes as they occur. Please do not hesitate to contact your Account Management Team if you have any questions or concerns.
Further information is also available at http://www.dol.gov/COBRA