COBRA Grace Period Extensions Disaster Relief

Under EBSA Disaster Relief Notice 2021-01, you may qualify for additional time to pay your COBRA premiums. If you need more time to pay your COBRA premiums, please notify our Customer Service team at 800-556-3137.

In April 2020, the U.S. Department of Labor and the U.S. Department of Treasury enacted a temporary new rule allowing, among other things, more time to pay your COBRA premiums. This rule sought to assist qualified beneficiaries having trouble paying premiums timely because of COVID-19 and applied only during the COVID Outbreak Period which begin on March 1^st 2020 and is still in effect.

On February 26, 2021, the Department of Labor issued EBSA Disaster Relief Notice 2021-01, clarifying that the plan or participant-related deadlines subject to such Outbreak Period relief would be disregarded until the earlier of one-year from the date they were first eligible for relief, or 60-days after the end of the National Emergency declaration. On that applicable date, the timeframes for the previously disregarded deadlines would resume.

On October 6, 2021, the IRS issued Notice 2021-58, which further clarified the Outbreak Period extensions of the COBRA election and initial premium payment periods. Notice 2021-58 advised that subject to a limited transition relief rule, qualified beneficiaries who elected COBRA coverage beyond the 60-day election period would have one year and 105 days to make their initial CORBA premium payment. For qualified beneficiaries who elected COBRA coverage within 60-days of receiving their Election Notice, the initial premium payment would be due in one year and 45-days following the date of their COBRA election. While the Outbreak Period remains in effect, under this latest guidance qualified beneficiaries must pay subsequent months’ COBRA premiums no later than one year from their original due dates, including the applicable 30-day payment grace period.

As a reminder:

• The rule only temporarily extended your premium due date.
• Monthly premiums are not forgiven.
• All coverages will be retroactively terminated if premiums are not paid in full.
• Coverage will end the last day of the month for which full premium was received
• If you received services, you may be responsible for any claims incurred once coverage ends.

American Rescue Plan Act (ARPA) COBRA Subsidy

If you lost group health plan coverage due to a reduction of hours or because you were involuntarily terminated, you may qualify to have COBRA premiums subsided at 100% through the American Rescue Plan Act. The subsidy is available for premiums from April 1^st 2021 through September 30^th 2021 for individuals who lost coverage on or after November 1^st, 2019 due to a reduction of hours or involuntary termination, who do not qualify for other group health plan coverage or Medicare, and would still be in their COBRA qualifying period during this time.

Employers are reporting individuals who may potentially be eligible for the subsidy to BenefitHelp Solutions. If you were reported to us as being potentially eligible for the subsidy, BenefitHelp Solutions will send you information related to the subsidy along with an enrollment and attestation form by May 31^st. If you are currently enrolled in COBRA and qualify for the subsidy, you will need to complete and return the attention form you receive from BenefitHelp Solutions within 60-days. If you are not currently enrolled in COBRA and qualify for the subsidy, you will need to complete and return both the enrollment form and attestation form you receive from BenefitHelp Solutions within 60-days.

If you are currently enrolled in COBRA and are eligible for the subsidy you will be refunded for any subsidized months that you have already paid for within 60-days from the date BenefitHelp Solutions receives your completed attestation form.