Issue 20b

The dust around the 2021 American Rescue Plan (ARP) has finally begun to settle, and second-chance COBRA offers have been mailed to assistance-eligible individuals (AEIs)! UPMC Benefit Management Services (BMS) has been sending out updated COBRA offers with language that reflects ARP regulations for qualifying events through Sept. 2021.

We hope your COBRA participants have gotten the information they needed and the burden of these new regulations hasn’t fallen on you and your team.

Because you are a mini-COBRA client, your AEI subsidized premiums are paid by your insurer per the ARP’s terms. BMS is committed to reporting your subsidized premiums accurately to ensure your records are correct. As such, we will provide monthly premium remittance reports for your AEIs.

With that in mind, we want to go over the COBRA premium subsidy afforded to you by the ARP and how it will be reported to you. Below is an example premium remittance report.

In the example – the premium reported is for an AEI’s coverage. The Summary page indicates in “red” that this will be subsidized by the insurer (in this case it is UPMC Health Plan.

For information about the mini-COBRA designation, please review the terms below.

Mini-COBRA terms:

• Group size: 2-19 employees on a typical business day during the preceding year
• Qualified beneficiaries (QBs):
  • Spouses (If the group allows domestic partners, they will be offered COBRA)
  • Dependent children
  • Surviving spouses
  • Children born to or placed for adoption with a subscriber
    • QB cannot be covered by or eligible to be covered by another private group health insurance plan or Medicare
• Continuous coverage requirement:
  • Employee/Dependent must have been on the plan for three continuous months prior to the qualifying event.
• Maximum coverage duration:
  • Nine months (versus 18-36-29 months on Federal COBRA)
• Qualifying events:
  • Death of a covered employee
  • Termination (other than by reason of gross misconduct) or reduction of hours of the covered employee’s employment
  • Divorce or legal separation of the covered employee from an eligible dependent
  • Medicare eligibility
  • A dependent child ceasing to be a dependent child under the requirements of the plan
  • Certain situations where the employer files for bankruptcy
• COBRA election period:
  • 30 days (versus 60 days on Federal COBRA)
• Covered benefit plans:
  • Medical and HRA
    • No dental or vision unless bundled with medical benefits
    • No standalone dental or vision

Please contact your dedicated BMS COBRA analyst with any questions you may have related to your mini-COBRA administration.