Employee Benefits

When the Affordable Care Act went into effect, it guaranteed that everyone who applied for individual health insurance would be approved for and enrolled in coverage. However, to prevent people from signing up for insurance only when they get sick, the ACA restricted enrollment to specific open enrollment periods—typically a period of three months from November to January. The DOL reminds plan sponsors that the guiding principle must be to act reasonably, prudently and in the interest of covered workers and their families for health, retirement and other employee benefit plans. Therefore, plan fiduciaries are encouraged to make reasonable accommodation to prevent loss of benefits or undue delay in payments and should minimize the possibility of individuals losing benefits because deadlines are missed. The DOL also recognizes there may be delays in claims processing and other ERISA requirements. The U.S. Departments of Labor , Treasury, and Health and Human Services have issued guidance extending deadlines for COBRA, special enrollment periods, benefit claims/appeals, employer notices and other disclosures.

If you’re losing COBRA continuation coverage because the coverage ran out or your former company stops contributing, causing you to pay the full cost, you qualify for a special enrollment period. If you lose health coverage through your company or a family member’s company, you might qualify for a special enrollment period. While participants still must pay COBRA premiums for any months they elect coverage, they can limit the premiums paid to the months they need coverage. In Example 1 above, suppose Adam knows in September that he incurred significant medical expenses only in June. He can elect COBRA coverage and pay the premiums for just two months of coverage. Your doctors and pharmacy may keep accepting your insurance; the insurance company may continue paying them and sending you the EOBs . Termination of benefits can be retroactive by weeks or months; you will be liable for every penny.

To verify that health coverage, you must submit documents showing that you were covered at least 1 day during the 60 days before your move. These documents may be correspondence from your insurance company, employer, or health coverage provider. If you’re moving from a foreign country or U.S. territory, you don’t need to provide this documentation. You’ll need to submit documents verifying that your coverage has ended or will end, along with the date it ends. Acceptable documents may be notices from your previous insurance company or your employer. You won’t qualify for a special enrollment period if you lost your job-based coverage because you voluntarily dropped coverage during the plan year or you lost your coverage because you didn’t pay your premium.

For disability, retirement and other plans, participants and beneficiaries have extra time to make claims for benefits and appeal denied claims. Plans, plan administrators and employers have extra time to provide certain COBRA notices. The regulations contain examples that, when combined below, illustrate how COBRA premium payments work under the suspended deadlines. The examples suppose a terminated participant timely elects COBRA and makes the February COBRA premium payment.

Health Insurance Alert: Beware Of Cobra Cancellations

Suppose the National Emergency ended April 30, 2020, in which case the suspension period would end June 29, 2020. The participant is not required to make the COBRA premium payments for March, April, May, or June until July 29, 2020 . Thus, the 30-day grace period for the payments for these months is July 29, 2020 . The participant is entitled to coverage under the group health plan until the premium payments are due. If by July 29, 2020 the participant has only paid two months of premium payments, these are applied to March and April 2020 and the participant is then not covered after April 2020.

For information on coverage through a particular group health plan, review the plan’s Summary Plan Description . Contact the plan administrator and request a copy if you don’t have one. The plan administrator may be able to send you one by email or direct you to a website where the SPD is posted.

Individuals involuntarily terminated 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 have a new election opportunity. This election period begins on February 17, 2009 and ends 60 days after the plan provides the required notice.

Finally, EBSA also issued a series of FAQs intended to assist participants and beneficiaries in understanding their rights and responsibilities under ERISA. The FAQs provide helpful links to additional resources related to health plan benefits, COBRA continuation coverage and pension plans. We have one month from the change-over date when we will still be employees of our current company; however we are required to use vacation pay or take unpaid leave during this period. Can employers combine two or more insurance plans into one offering. The employee may choose to except the offer or decline the coverage. We value health and well-being and provide a variety of market-competitive benefits to help our employees and their families to be proactive about their health and successfully plan for their future. Similarly, the Departments recognized that group health plans may have difficulty in complying with certain notice obligations.

Verifying Your Qualifying Life Event And Enrolling In Coverage

There is some relief for people whose companies already offer a QSEHRA or ICHRA, though. If you’re looking for a health insurance policy because your company is offering a QSEHRA or ICHRA, you won’t be able to purchase one until open enrollment—but you will be able to submit your qualified medical expenses for reimbursement. The only thing you need to do is include these reimbursements as part of your gross income. Once you get a policy, you’ll be able to receive these reimbursements tax-free. In general, the documentation required depends on your qualifying life event. We’ll go over two common reasons people qualify for a special enrollment period, the documentation they should submit, the timeline for submitting that coverage and picking a policy, and the time coverage starts once the first premium payment is made.

Once its review is complete, the Claim Administrator must state, in writing, the results of the review and indicate the Plan provisions upon which it based its decision. An appeal concerning denied payment of a claim should be filed with your medical insurance company. Full-time employees of the City of Cleveland are eligible for $15,000 in group life insurance coverage, at no cost to the employee. Employees may purchase additional group term life insurance up to $300,000 through the Optional Life Insurance Plan. The current Optional Life Insurance policy provides accidental death & dismemberment benefits and offers free Will preparation. Full-time employees are eligible to cover themselves and eligible family members for vision care insurance. Timely enrollment is required for coverage, which becomes effective the first of the month following the date of hire.

A premium is considered timely paid if it is made not later than 30 days after the first day of the coverage period. ARAG will provide a written reply to your request for appeal and will notify you of its determination no later than 60 days after ARAG receives your request for review. If ARAG determines that an extension of time is required for processing your claim, ARAG will provide you with a written notice of the extension within 60 days after your request for review.

What Are Some Examples Of Benefits?

If you disagree with denial of your claim under the plan, you have the right to appeal. If you choose to appeal you must file your appeal with ARAG in writing no later than 60 days after receipt of your denial. If you do not file your appeal within 60 days you will lose any right to further review of your claim. The Insurance Company has 45 days from the date it receives your request to review your claim and notify you of its decision. Under special circumstances, the Insurance Company may require more time to review your claim. If this should happen, the Insurance Company must notify you, in writing, that its review period has been extended for an additional 45 days. Once its review is complete, the Insurance Company must notify you, in writing, of the results of the review and indicate the Plan provisions upon which it based its decision.

Note that many plans require employee contributions, and those contributions are likely still due, even if you are not being paid and those contributions are no longer being automatically deducted from your wages or salary. COBRA continuation coverage may be terminated for failure to pay premiums timely.

Coverage provides one eye exam every 24 months for adults, one eye exam every 12 months for children, and a variety of choices for the purchase of glasses or contacts through in-network providers. Full-time employees are eligible to cover themselves and eligible family members for health care insurance.

The extended deadlines apply to plans governed by the Employee Retirement Income Security Act of 1974 , and governmental plans. COBRA coverage can be a lifeline for employees who lost their jobs during the pandemic, allowing them to continue with a health plan they’re familiar with, often at a cost lower than they could find through the Affordable Care Act marketplace. On May 4, the DOL and IRS jointly published Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak. The final rule extends time frames affecting participants’ rights to health care coverage, portability and continuation of group health plan coverage under COBRA, and it extends the time for plan participants to file benefit claims or appeal denied claims. A benefit provider is an organization that charges premiums in exchange for health care coverage or other services. When shopping for benefit providers, businesses have several options – consult a broker, work with insurance carriers directly or join a professional employer organization that will negotiate the contract and administer the benefits on its behalf. From the employee’s perspective, the group benefits provider is often the employer.

That can be better than trying to buy insurance on your own, especially if a family member has a pre-existing condition. Examples of traditional benefits include health and dental care, life insurance and retirement savings plans. Unique benefits, on the other hand, consist of education assistance, paid parental leave, telecommuting and more. Employers who succeed in keeping their employees engaged often find the right mix of both types of benefits. In Example 2, the Outbreak Period is disregarded for purposes of determining Individual B’s special enrollment period. Individual B and her child qualify for special enrollment into her employer’s plan as early as the date of the child’s birth. Individual B may exercise her special enrollment rights for herself and her child into her employer’s plan until 30 days after June 29, 2020, which is July 29, 2020, provided that she pays the premiums for any period of coverage.

• The regulations contain examples that, when combined below, illustrate how COBRA premium payments work under the suspended deadlines.
• The participant is not required to make the COBRA premium payments for March, April, May, or June until July 29, 2020 .
• The examples suppose a terminated participant timely elects COBRA and makes the February COBRA premium payment.
• For disability, retirement and other plans, participants and beneficiaries have extra time to make claims for benefits and appeal denied claims.
• Plans, plan administrators and employers have extra time to provide certain COBRA notices.

You have 180 days from the date you were notified of the denial of benefit coverage or claim payment to file your appeal. A request for coverage that was denied as specifically excluded in your medical plan’s Description of Benefits or for coverage that was denied based on medical necessity determinations are reviewed as appeals through the Internal Appeals Process. For post-service claims, the Claim Administrator will notify you of an adverse determination within a reasonable period of time, but no later than thirty days after receipt of the claim. You will be given at least forty-five days from receipt of the notice within which to provide the specified information. Our experience includes FICA taxation test cases that involve tipped employees, medical residents, employee stock purchase plans, and the treatment of downsizing payments. The Ohio Deferred Compensation Program offers employees the option of participating voluntarily in a tax-deferred supplemental retirement plan. The goal is to save for retirement while deferring taxes on your earnings.

Benefits

I have been providing cleaning services for a company for the last 11 years. Never once have been paid any benefits such as paid vacation, health insurance or overtime. The Claim Administrator has 60 days from the date it receives a request to review the claim and provide its decision. Under special circumstances, the Claim Administrator may require more time to review the claim. If this should happen, the Claim Administrator must provide notice, in writing, that its review period has been extended for an additional 60 days .

If an employee elects to participate in the deferred compensation program, he or she decides on the amount to be contributed biweekly, which can be increased or decreased at any time. That amount will be deducted from the employee’s paychecks on a pre-tax basis and deposited to the account the employee has established with Ohio Deferred Compensation. Full-time employees are eligible to cover themselves and eligible family members for dental care insurance.

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.

Any extension may last no longer than 60 days after the termination of the initial 60-day period. During the pandemic, however, some employers are choosing to pay for a former employee’s COBRA coverage if the person has been laid off, or to do so for current employees who lost group health plan coverage when they were furloughed or had their hours reduced. Under COBRA, employees and dependents who lose active coverage as a result of a qualifying event, such as termination of employment or reduction of hours, normally have 60 days to elect continuation of coverage after receiving a COBRA election notice. Under the rule, the 60-day timeframe doesn’t start until the end of the Outbreak Period. Department of Labor and the IRS released a new final rule that temporarily extends the period in which eligible employees can elect COBRA health insurance coverage, and the deadline for them to begin making COBRA premium payments. The idea behind COBRA is that the employee will find a job, with health insurance, before the 18 months are up.