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Important Information about Your Rights to COBRA Continuation Coverage During the COVID–19 Pandemic

This summary provides important information about temporary relief that may be available to you and/or your family members if you are enrolled in (or become newly entitled to) continuation of your employer’s group health coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”). This summary does not fully describe your COBRA rights. It is a supplement to the COBRA General Rights Notice that you received upon becoming eligible for your employer’s group health coverage (the “General Notice”). If you have experienced a COBRA qualifying event, this summary also is a supplement to the COBRA Specific Rights Notice (“Election Notice”).

On April 28, 2020, the U.S. Department of Treasury, Internal Revenue Service, and the Department of Labor, Employee Benefits Security Administration, issued joint guidance providing temporary relief to benefit plans and participants during the COVID–19 pandemic (the “Joint Guidance”). This summary describes the temporary relief specific to COBRA continuation coverage. To review the Joint Guidance and learn about other temporary relief that may be available to you, click here

Under the Joint Guidance, certain deadlines imposed on COBRA qualified beneficiaries are temporarily extended by disregarding days falling within the “Outbreak Period”, which is generally defined in the guidance as the period from March 1, 2020 through 60 calendar days after the announced end of the National Emergency that has been declared for the COVID-19 pandemic. 

The Joint Guidance would temporarily extend for the duration of the Outbreak Period the following deadlines under COBRA: 

  • The 60-day period within which an employee or a covered dependent must notify the plan of an initial COBRA qualifying event due to divorce, legal separation, or other loss of dependent eligibility.
  • The 60-day period within which a qualified beneficiary may elect to continue employer-sponsored group health coverage under COBRA, retroactive to the date of the COBRA qualifying event.
  • If COBRA continuation coverage is elected, the [45-day] deadline to submit the first COBRA premium payment, as well as the [30-day] deadline to submit recurring COBRA premium payments.
  • The 60-day period within which a qualified beneficiary must notify the plan of a disability determination, or of a second COBRA qualifying event, in order to extend the COBRA continuation coverage period. (The 30-day deadline to notify the plan if the qualified beneficiary is no longer disabled would also be extended.) 

Please note that the Joint Guidance also provides relief to benefit plans by extending the deadlines to furnish the General Notice and/or the Election Notice. While COBRA Complete will endeavor to continue providing such notices to you within the timeframes required under COBRA, please note that any delay in your receipt of a notice should not affect your continuation coverage rights under COBRA. 

For Questions and for More Information: If you have any questions about the information in this summary or your COBRA continuation coverage rights during the COVID–19 pandemic, please contact COBRA Complete at 855-893-0011 or COBRAComplete@healthaccountservices. com

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