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UPDATE: Employee Benefits Security Administration (EBSA) Disaster Relief Notice 2021-01

As a follow-up to our communication sent on March 8, we have additional information to share with you regarding the recently announced Disaster Relief Notice 2021-01 and what this means for certain members.

COBRA Participants in their Tolling Period
We are currently identifying individuals who have the end of their 12-month tolling period approaching or whose 12-month tolling period has expired. A separate communication will be sent out to those individuals advising them that at the end of their upcoming extension or exhaustion of the extension, they will have 30 days from the date of the correspondence to remit premium payment in full to Excellus BCBS in order to remain active.

  • If they do not make the required payment, their coverage will be retro terminated back to the date of their last full or partial payment. If we do not receive payment within 30 days, all applicable carriers will be notified of the individual’s termination date.

Electing COBRA coverage for individuals with future qualifying event dates

  • Effective immediately, individuals who have a qualifying event for COBRA coverage will no longer be immediately enrolled for COBRA coverage unless premium payment is received in full within 45 days of the election packet being received.
  • Individuals will continue to have the 12-month tolling period apply to elect COBRA coverage from the date of an individual's qualifying event. If the individual subsequently makes their initial premium payment, their COBRA coverage will start retroactive to their initial qualifying date.

COBRA Subsidy included in Stimulus Proposal
For company sponsored health plans, Congress recently passed legislation stating that the federal government will pay 100% of COBRA premium payments (which includes the 2% administrative fee) beginning April 1, 2021 through September 30, 2021 for qualified beneficiaries who:

  • Are currently eligible for COBRA and who did not voluntarily terminate their employment
  • Declined COBRA earlier but who are still within their COBRA election period had they elected COBRA, or
  • Dropped COBRA but would still be within their COBRA period if they had not dropped their COBRA coverage.

Employers will be able to obtain the subsidy through a tax credit against their quarterly taxes. While model notices and regulations relating to the COBRA subsidy legislation are expected, we are working to understand and implement this legislation.

We will continue to provide you with the latest information as we receive it. As always, if you have any questions or need additional clarification, please contact your dedicated account representative.

 

 
 
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