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Important information regarding the American Recovery and Reinvestment Act (ARRA) Mini-COBRA Premium Subsidy

Here are some instructions and forms regarding your responsibilities related to COBRA continuation coverage, state continuation coverage (mini-COBRA) as well as those for premium assistance coverage as part of the American Recovery and Reinvestment Act (ARRA).

 

Connecticut small-group employers with 19 or fewer employees

Federal law requires that insurers (e.g.ConnectiCare) send a notice about ARRA and the request for treatment as an Assistance Eligible Individual (AEI) directly to the individuals who may be eligible for the program during an initial special enrollment period. ConnectiCare has sent the notice and request to all former employees associated with your group who were termed between 9/1/08 and 3/1/09 as well as former employees who currently have active mini-COBRA coverage (according to our records). These individuals may choose to pursue this subsidy coverage and if so, will contact you for completion of the necessary election notice form for Connecticut mini-COBRA .Once completed, it will need to be forwarded to ConnectiCare.

Please take a moment to review the election notice form for Connecticut mini-COBRA. You will see that it contains all of the elements of a standard COBRA election notice, plus information about premium assistance.

Important steps to follow:

Section 1A, page 2. This portion needs to be completed for individuals who are eligible for the premium subsidy, but do not currently have mini-COBRA coverage. ARRA provides a mini-COBRA coverage special election period for these individuals. Please note that the premium assistance program does not extend the duration of mini-COBRA coverage. You must determine the date the individual became eligible for mini-COBRA, calculate the length of mini-COBRA according to the applicable qualifying event, and then calculate the end date for mini-COBRA, which will be the same end date as if the individual enrolled for mini-COBRA when first eligible.

Section 1A, page 6. Fill in your address where the individual should send mini-COBRA premium payments. Please note that ConnectiCare will continue to bill you for all mini-COBRA premiums due from your former employees.

Section 1A, page 7. Fill in your contact information for former employees who want general information about their rights under your benefit plan.

Section 1B, page 8. For the special election period, continuation coverage will begin on March 1. The end date will depend on the individual's situation. Fill in the premium for the coverage the employee had while actively covered under your plan. Fill in the amount the individual must pay monthly when eligible for the premium assistance program. This is generally 35% of the full premium, but is reduced if you are contributing any amount to the individual's premium.

Section 1C, page 8. Fill in your contact information for former employees who want general information about their continuation coverage. You are responsible for administering mini-COBRA continuation coverage under your plan.

Section 2A, page 9. Fill in your address where former employees send their mini-COBRA election notices.

Section 3C, page 11. You must approve or deny the individual's Request for Treatment as an Assistance Eligible Individual. If you approve the request, check the "Approved" box and fill in the requested information. When you approve a request, send the entire form to ConnectiCare. Keep a copy for your records and give a copy to the individual. If you deny the request, check the "Denied" box, along with one of the reasons listed (including an explanation where necessary) and give the form to the individual. Keep a copy for your records. The individual has a right to appeal your denial to the federal government. Make sure you completely sign and date all approvals and denials. Attached is a link to the form ConnectiCare will send to your former enrollees who our records indicate have mini-COBRA coverage as of March 1, 2009.

 

Massachusetts small-group employers with 19 or fewer employees

Federal law requires that insurers (e.g. ConnectiCare) send a notice about ARRA and the request for treatment as an Assistance Eligible Individual (AEI) directly to the individuals who may be eligible for the program during an initial special enrollment period. ConnectiCare has sent the notice and request to all former employees associated with your group who currently have active mini-COBRA coverage and were terminated between 9/1/08 and 3/1/09 (according to our records). These individuals may choose to pursue this subsidy coverage and if so, will contact you for completion of the necessary election notice form.for Massachusetts mini-COBRA. Once completed, it will need to be forwarded to ConnectiCare. Please take a moment to review the election notice form.

Important steps to follow:

Section 1A, page 2. Fill in your contact information for former employees who want general information about their rights under your benefit plan.

Section and 1C, page 3. You must approve or deny the individual's Request for Treatment as an Assistance Eligible Individual. If you approve the request, check the "Approved" box and fill in the requested information. When you approve a request, send the entire form to ConnectiCare. Keep a copy for your records and give a copy to the individual. If you deny the request, check the "Denied" box, along with one of the reasons listed (including an explanation where necessary) and give the form to the individual. Keep a copy for your records. The individual has a right to appeal your denial to the federal government. Make sure you completely sign and date all approvals and denials. Attached is a link to the form ConnectiCare will send to your former enrollees who our records indicate have mini-COBRA coverage as of March 1, 2009.

election notice form for Massachusetts mini-COBRA

 

Ongoing employer responsibility for Connecticut and Massachusetts small-group employers with 19 or fewer employees

Employers must provide state continuation (mini-COBRA) notification for employee terminations as of March 1, 2009, and forward. Employers must also provide AEI election when applicable, and are required to notify ConnectiCare of all AEI-eligible enrollees.

 

For Connecticut and Massachusetts employers with 20 or more employees (For whom we do not bill the individual directly for COBRA premiums)

There are no changes in the COBRA notification and billing policy for those groups, with 20 or more employees, who self-administer COBRA benefits. ConnectiCare will expect to receive 100% of the billed premium. We do not need any notice of who is getting the COBRA subsidy.

 

For Connecticut and Massachusetts employers with 51 or more employees (For whom we bill the individual directly for COBRA premiums)

  • Employers for whom we bill the individual directly for COBRA premiums must notify ConnectiCare which new or existing COBRA beneficiaries qualify as AEIs.
  • ConnectiCare will bill the AEI 35% of their total premium while billing the employer the balance of the premium or 65%.
  • For these employers who have new COBRA-eligible enrollees, please use our existing enrollment/change forms to correctly indicate an enrollee’s eligibility and to note that he or she is an AEI.
  • For these employers that have existing COBRA-eligible enrollees, we will change the enrollee’s status to correctly identify AEIs upon receipt of written instructions from you.
  • If you are providing us with a roster of COBRA-eligible enrollees, the list needs to indicate which are AEI’s and give their full name, address, Social Security Number and effective date.

 

COBRA subsidy billing adjustments will first appear on the June invoice, received in May.

For more information regarding COBRA, visit the Department of Labor Web site at: http://www.dol.gov/ebsa/cobra.html