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COBRA ARRA First Payment
Benefits & Compensation
COBRA ARRA First Payment
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Like all of you, I've been patiently waiting for the official COBRA ARRA guidance and model notices from the DOL. Has guidance been issued regarding when the first payment (from the former employee/de
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Forums » Topic Forums » Benefits & Compensation » COBRA ARRA First Payment
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COBRA ARRA First Payment
posted at 3/18/2009 4:45 AM EDT
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Posts: 63
First: 1/3/2003 Last: 8/10/2011 |
Like all of you, I've been patiently waiting for the official COBRA ARRA guidance and model notices from the DOL. Has guidance been issued regarding when the first payment (from the former employee/dependent)is due for those who where on COBRA (prior to 3/1/09) and those who are COBRA eligible as of 3/1/09? 45 days (after election)? Just making sure I didn't miss it in all the hoopla and initial information.
Thanks! |
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COBRA ARRA First Payment
posted at 3/18/2009 6:55 AM EDT
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Posts: 2146
First: 2/15/2006 Last: 9/14/2011 |
It is my understanding that the timeframes haven't changed, but would be the same as a terminated employee who is getting the original notice of COBRA. So yes, the 60 days to elect then the 45 day window would still apply. |
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COBRA ARRA First Payment
posted at 3/19/2009 10:52 AM EDT
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Posts: 11
First: 11/24/2008 Last: 8/19/2011 |
http://www.dol.gov/ebsa/COBRAmodelnotice.html |
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COBRA ARRA First Payment
posted at 3/19/2009 12:00 PM EDT
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Posts: 63
First: 1/3/2003 Last: 8/10/2011 |
Update: After reviewing the Model notices, I spoke to a local DOL rep. Current COBRA enrollees are expected to continue paying COBRA monthly premiums (premium reduction if eligible) on the same payment schedule put in place when they initially enrolled in COBRA. |
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COBRA ARRA First Payment
posted at 3/31/2009 12:12 PM EDT
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Posts: 19
First: 4/28/2008 Last: 12/21/2009 |
I am a bit confused the letters for those former employees who turned down COBRA the first time. We have until April 17 to get them out, but do we make the date March 1 or April 1? For example, if they said NO to COBRA but had claims in March they want COBRA to cover, can they do that? I appreciate the feedback. |
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COBRA ARRA First Payment
posted at 4/1/2009 8:01 AM EDT
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Posts: 63
First: 1/3/2003 Last: 8/10/2011 |
Are you referring to the date of the letter?
According to everything I have read, they are eligible to pick up COBRA. See below copied from the US DOL website: Q6: Who is eligible for a new, second election opportunity for COBRA coverage? Qualified beneficiaries whose qualifying event was an involuntary termination of employment during the period from September 1, 2008 through February 16, 2009 who did not elect COBRA when it was first offered OR who did elect COBRA but are no longer enrolled (for example, those who dropped COBRA coverage because they were unable to continue paying the premium) have a new, second election opportunity. Individuals eligible for the extended COBRA election period must receive a notice informing them of this opportunity. This notice must be provided by April 18, 2009 and individuals have 60 days after the notice is provided to elect COBRA. However, this special election period does not extend the period of COBRA continuation coverage beyond the original maximum period (generally 18 months from the employee's involuntary termination). COBRA coverage elected in this special election period begins with the first period of coverage beginning on or after February 17, 2009. Under ARRA, this special election period opportunity is not required to be provided with respect to State continuation coverage that is provided pursuant to State insurance law. A State can take action, however, to provide an additional election period in its continuation coverage program for individuals involuntarily terminated from September 1, 2008 through February 16, 2009 in order for them to request premium assistance based upon involuntary termination occurring during that period. For more information on rights and responsibilities regarding election periods under State law, contact your State insurance commissioner's office or CMS at www.cms.hhs.gov/COBRAContinuationofCov. Hope this helps! |
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