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COBRA Subsidy Ext. FAQs

 

Extension of the
COBRA Premium Subsidy
 FAQs

INTRO:

On April 15th, Congress voted to extend the COBRA Subsidy until May 31st, 2010.   The COBRA premium subsidy is now available to individuals who lose their coverage due to an involuntary termination of employment which occurs on or before May 31, 2010.

The COBRA premium subsidy timeline:

•  The stimulus package, which was enacted in February 2009 as the American Recovery and Reinvestment Act of 2009 (ARRA), temporarily reduces the premium for COBRA or comparable State continuation coverage for eligible individuals.

•  The Department of Defense Appropriations Act, 2010 (2010 DOD Act) amended ARRA to extend the period to qualify for the COBRA premium reduction, as well as extended the maximum period for receiving the subsidy an additional six months (from nine to 15 months).

•  The Temporary Extension Act of 2010 (TEA) was signed by the president on March 2, 2010. TEA amended ARRA to further extend the period to qualify for the COBRA premium reduction until March 31, 2010. TEA also provides that an involuntary termination of employment that occurs on or after March 2, 2010 but by March 31, 2010 is a qualifying event for purposes of ARRA if it was preceded by a qualifying event that was a reduction of hours occurring at any time from September 1, 2008 through March 31, 2010.

•  On April 15th, Congress voted to extend the COBRA Subsidy until May 31st, 2010

FAQs:
 

  1. Which individuals are eligible for the COBRA Subsidy Extension?

    Employees (as well as their covered spouse and covered dependents) who lose their group insurance coverage due to the involuntary loss of their job or reduction of hours (other than for gross misconduct) on or after September 1, 2008 but before May 31, 2010 are eligible for the COBRA Subsidy. These individuals are known as “Assistance Eligible Individuals” or “AEIs”.

To be considered an “assistance eligible individual” and receive reduced premiums you:

·         must have a continuation coverage election opportunity (“qualifying event”)* related to an involuntary termination of employment that occurred at any time from September 1, 2008 through May 31, 2010;

·         must elect the coverage (within the appropriate timeframes);

·         must not be eligible for Medicare; and

·         must not be eligible for coverage under any other group health plan, such as a plan sponsored by a successor employer or a spouse’s employer.

*TEA also provides that individuals who lost coverage because of a qualifying event that was a reduction of hours that occurred any time from September 1, 2008 through March 31, 2010 may be eligible for the premium reduction if the employee is then involuntarily terminated on or after March 2, 2010 and no later than March 31, 2010. The premium assistance for these individuals begins with the first period of coverage following the employee’s involuntary termination (that occurs on or after March 2, 2010 through March 31, 2010). TEA also provides a new election opportunity for these individuals if they did not elect (or elected and discontinued) COBRA.

Note: A reduction of hours is a qualifying event when the employee and his/her family lose coverage because the employee, though still employed, is no longer working enough hours to satisfy the group health plan’s eligibility requirements.

  1. What is the amount of the COBRA Subsidy?

    The subsidy is 65% of the AEI’s required monthly premium contribution. Typically, AEIs will therefore be required to pay only 35% of the required premium to the Employer (or directly to the insurer in some state continuation situations). Note: If the Employer is paying a portion of the COBRA premium on behalf of an AEI, the subsidy would only be for 65% of the AEI’s remaining premium. The Employer’s contribution in that situation is not subsidized.
     
  2. What is the duration of the COBRA Subsidy?

    The COBRA Subsidy is provided to an AEI for up to 15 months. The subsidy ends if the AEI becomes eligible for other comprehensive group health coverage or Medicare. For subsidies of state continuation coverage, the subsidy ends if the individual’s state continuation coverage period expires. The subsidy does extend a state’s continuation coverage period. (return)
     
  3. Does the new COBRA Subsidy Extension lengthen the amount of time an AEI may stay on COBRA?

    No.
     
  4. I was on the COBRA Subsidy from March 2009 thru November 2009. I paid non-subsidized premiums in the month of December and again in January. When do I start paying the subsidized rates again?

    The extension is actually retroactive. AEIs who remain eligible for subsidy assistance will receive a credit for any non-subsidized premiums paid upon expiration of their original subsidy. This premium will be automatically credited to future coverage months. However, should you desire a refund of any overpaid premium, please contact Admin America to process this request.
     
  5. How can I contact Admin America?

    Admin America’s COBRA Department can be reached at: 678-578-4338. Alternatively, as Admin America anticipates a higher call volume, you may email: cobra@adminamerica.com.
     
  6. If an AEI becomes eligible for other comprehensive group health coverage or Medicare but chooses not to enroll in that coverage, do they still lose the COBRA Subsidy?

    Yes.
     
  7. If an AEI becomes eligible for other comprehensive group health coverage or Medicare but chooses not to enroll in that coverage, do they lose the right to continue under COBRA without the COBRA Subsidy?

    No. They can continue their COBRA coverage if they so choose; the federal government just will not subsidize the premium any longer.
     
  8. What if the AEI fails to notify the Employer once they are eligible for other comprehensive group health coverage or Medicare?

AEIs who fail to provide notice of eligibility for other coverage or Medicare are subject to penalties equal to 110% of any subsidies paid on their behalf after the date of eligibility.

This page was last updated on 01/28/2010


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