Tuesday, January 26, 2010

COBRA Extension Impacts Small Ohio Employers

The COBRA subsidy provided under the federal stimulus bill was recently extended under a defense spending bill (Department of Defense Appropriation Act of 2010) to provide for an additional 6 months of COBRA premium subsidy (from 9 months to 15 months), as well as an extension of the subsidy eligibility period to February 28, 2010.



Employers with fewer than 20 employees who are covered by state continuation coverage ("mini-COBRA") rather than the federal law are also impacted by the new bill. The Ohio Department of Insurance has issued a guidance sheet that details how the bill impacts small Ohio employers and what employers and insurers must do to comply. Here are a few highlights:



Individuals receiving state continuation coverage under Ohio law may now be eligible for up to 12 months of federal subsidy (but not the entire 15 months provided under federal COBRA law).
Employees who are involuntarily terminated through February 28, 2010 are eligible for the subsidy.
Employers/insurers are not required to offer retroactive state continuation coverage to employees who declined it. However, they must notify individuals currently enrolled in state continuation coverage of the potential subsidy extension. The Ohio Department of Insurance has provided a modified version of the model notice issued by the DOL. This notice must be distributed no later than February 17, 2010.
Please review the guidance sheet for more detailed information about the bill, including how the subsidy and remaining premium are paid. If you have any questions, please contact Cindy LaQuatra at 216-393-1848 or by email at claquatra@benefitsresourcegroup.com .