On April 29, 2020, the Department of Labor and Department of Treasury issued joint guidance extending certain deadlines related to retirement, health and welfare plans in response to the current COVID-19 pandemic. We want to make sure you are aware of how these deadline extensions impact COBRA and how Benefit Strategies is administering them.
Although plan administrators have had their 14 day deadline to provide a COBRA election notice to Qualified Beneficiaries extended, we have had no interruption in our operations and will continue to get these notices out within 2 business days. If you need a COBRA election notice sooner for any reason, please contact your Account Manager and they will be able to assist you.
We want to assure you that we are only continuing coverage and reinstating coverage for COBRA enrollees that are current in their payments. Please continue reading for details.
Key terms and time periods to know:
We are continuously monitoring changes in COBRA regulations and we will update this page as quickly as possible when we have new information. We have a similar page that individuals are re-directed to when they log in to the COBRA platform via benstrat.com. We have encouraged them to reach out to our Customer Service team if they have any questions.
If you have any questions on the information on this page, please reach out to firstname.lastname@example.org
Although extensions are permitted, all COBRA communications COBRA enrollees receive from Benefit Strategies will continue to reflect the standard COBRA timeframes. We are strongly encouraging enrollees to continue following these timeframes to prevent potential disruption of coverage.MONTHLY PAYMENTS:
Enrollees now have additional time to make their monthly payments. Under standard COBRA rules they have a 30-day grace period after the due date to still make their payment. If the payment is not received by the end of the grace period, coverage is terminated and cannot be reinstated. During the Outbreak Period, if a payment is not made by the end of the grace period, their coverage will be interrupted. However, they can make their past due premium payments at any point up until 30 days after the Outbreak Period ends and their coverage will be restored.For example:
Under standard COBRA Rules, if their premium is due 6/1/2020, they have until 6/30/2020 to make their payment. After 6/30/2020, their coverage is terminated with the carrier back to 6/1/2020. Late payments cannot be accepted, and their coverage cannot be restored.
During the Outbreak Period if their payment is received on 07/05/2020, we can accept their late payment and restore their coverage. If they are unable to pay their full monthly premium in one payment, we strongly encourage that they make smaller payments instead, when they are able to do so, such as on a weekly basis. This will prevent large outstanding balances from building up. For example, they have paid in full through March 2020, and now owe for April 2020. If the National Emergency is declared over on 6/29/2020, then the Outbreak Period will be determined to end 60 days after that on 8/28/2020. They then have until 30 days after the end of the Outbreak Period (9/27/2020) to pay their account in full and have coverage restored. If they waited to pay until the 30th day after the end of the Outbreak Period, they would then owe for April, May, June, July, and August. Failure to pay all past months within in the 30-day period after the Outbreak Period ends will result in permanent termination of their COBRA coverage as of the end of the last month fully paid for.QUALIFYING EVENTS
COBRA enrollees are being told to notify Benefit Strategies as soon as possible of any qualifying events even though the deadline to notify has been paused. If premiums need to be adjusted due to the qualifying event, specifically if they increase, the enrollee risks accumulating a very large balance. This is because they will owe the increased premium amount back to the date the qualifying event change became effective.COBRA END DATE
The guidance released does not allow an extension of the COBRA period past the previously allowed number of months. For example, if someone were previously allowed 18 months, it will remain 18 months. COBRA rules only allow an extension of an original COBRA coverage period if the enrollee has an applicable qualifying event or disability approval.
They can still submit an appeal of the denial. We are informing them to keep in mind that if their coverage was already terminated and an appeal is approved, all past due premiums will need to be brought current in order for coverage to be reinstated with the carrier.
Although they can now wait to make their initial payment, coverage is not reinstated with the carrier until they’ve made their full initial payment. For example, if their first day of COBRA is 4/1/2020 and they do not elect until 6/28/2020, they will need to pay the total monthly premium for April, May, and June to satisfy their initial payment and be reinstated with their insurance carrier.
Their election deadline has now been extended through the 60 day period following the end of the National Emergency. However, their coverage will not be reinstated with the insurance carrier until they make their election and make full initial payment. For example, if their first day of COBRA is 4/1/2020 and they do not elect until 6/28/2020, they will need to pay the total monthly premium for April, May, and June to satisfy their initial payment and be reinstated with their insurance carrier.
Paying several months of past premiums all at once may be a financial challenge for some people. If that is their situation, we are recommending that if they intend to elect COBRA, they do so and make their initial payment as soon as they can.
If their last day to elect COBRA was on or after 3/1/2020, they can elect now as election deadlines were paused on 3/1/2020. They can elect at any point during the National Emergency and the 60 day period after it ends. However, coverage will not be reinstated with the insurance carrier until their full initial payment is made. For example, if they elect on 5/22/2020 and their first day of COBRA is 1/1/2020, they will need to make payment for January, February, March, April, and May for coverage to be reinstated.