| Greetings! Welcome
to the January edition of the PBG Newsletter. To follow, we bring you more information
the COBRA subsidy extension, Partners Benefit Group updates, same-sex marriage
& domestic partner COBRA compliance, 5500 Filing, and Blue Cross Blue Shield's
new interest charge on delinquent premiums. As always, please contact our office
directly with any specific questions or requests for additional information!
Per the U.S. DOL - ARRA, as amended
by the Department of Defense Appropriation Act, 2010 (2010 DOD Act), mandates
that plans notify certain current and former participants and beneficiaries about
the premium reduction. The Department created model notices
to help plans and individuals comply with these requirements. Each model notice
is designed for a particular group of qualified beneficiaries and contains information
to help satisfy ARRA's notice provisions, including those added by the 2010 DOD
Act. Plans subject to the Federal COBRA
provisions must provide the updated General Notice to all qualified beneficiaries
(not just covered employees) who experienced a qualifying event at any time from
September 1, 2008 through February 28, 2010, regardless of the type of qualifying
event, and who have not yet been provided an election notice. This model notice
includes updated information on the premium reduction as well as information required
in a COBRA election notice. Note: Individuals who experienced
a qualifying event (that was a termination of employment) in December 2009 but
who were not eligible for COBRA coverage until January 2010 were likely not provided
proper notice. These individuals should get the updated General Notice AND the
full 60 days from the date the updated notice is provided to make a COBRA election. Plan administrators
must provide notice to certain individuals who have already been provided a COBRA
election notice that did not include information regarding ARRA, as amended. This
model Premium Assistance Extension Notice includes information about the
changes made to the premium reduction provisions of ARRA by the 2010 DOD Act.
Listed below are the affected individuals and the associated timing requirements. - Individuals
who were "assistance eligible individuals" as of October 31, 2009 (unless
they are in a transition period - see below), and individuals who experienced
a termination of employment on or after October 31, 2009 and lost health coverage
(unless they were already provided a timely, updated General Notice) must
be provided notice of the changes made to the premium reduction provisions of
ARRA by the 2010 DOD Act by February 17, 2010;
- Individuals who
are in a "transition period" must be provided this notice within 60
days of the first day of the transition period. An individual's "transition
period" is the period that begins immediately after the end of the maximum
number of months (generally nine) of premium reduction available under ARRA prior
to its amendment. An individual is in a transition period only if the premium
reduction provisions would continue to apply due to the extension from nine to
15 months and they otherwise remain eligible for the premium reduction.
Note:
To some extent, the groups listed above overlap - creating a situation where an
individual may be entitled to multiple notices. Providing the Premium Assistance
Extension Notice by the earliest date required will satisfy the notice requirement(s). Insurance issuers that provide
group health insurance coverage must send the updated Alternative Notice
to persons who became eligible for continuation coverage under a State law. Continuation
coverage requirements vary among States and issuers should modify this model notice
as necessary to conform it to the applicable State law. Issuers may also find
the model Premium Assistance Extension Notice or the updated model General
Notice appropriate for use in certain situations.
Members Insurance Agency, LLC, a wholly-owned
subsidiary of the Massachusetts Credit Union League, the New Hampshire Credit
Union League and the Credit Union Association of Rhode Island, announced on recently
it has formed a permanent alliance with Partners Benefit Group (PBG). As a leader
in creative cost containment strategies and with their direct claims management
capabilities, PBG is able to create options seldom implemented by insurance generalists.
Through its new alliance with PBG, Members Insurance Agency aims to maximize the
value of the employee benefits programs being made available to the 256 credit
unions located throughout Massachusetts, New Hampshire and Rhode Island.
Recently, there has been some confusion
surrounding COBRA/State Continuation as it applies to same sex spouses and domestic
partners. We'd like to take this opportunity to remind everyone what the implications
are. MA insurance carriers will treat same sex spouses of subscribers the same
as opposite sex spouses to the extent permitted by law. Same sex spouses will
be considered dependents and eligible for coverage just as opposite sex spouses
have been. In addition, same sex spouses will be covered under State Continuation
of Coverage provisions (for groups 2-19 employees) and the state's divorced spouses
provisions. They will not, however, be covered under Federal COBRA
continuation provisions since same sex marriage is not recognized under the federal
law. Additionally, neither same sex spouses nor domestic partners are eligible
for the subsidy under ARRA. This applies to companies subject to State Continuation
and Federal COBRA.
It is also important to note that domestic partners
are not defined as qualified beneficiaries under Federal COBRA provisions or State
Continuation and therefore, are not eligible for COBRA.
With the start of 2010, the U.S. Department
of Labor (DOL) has converted to a total electronic system for online filing of
Forms 5500 and the new 5500-Short Form. The all electronic EFAST2 system lets
benefit plan administrators submit and access filings online. Filers must submit
the 2009 and 2010 annual return/report forms and schedules electronically through
EFAST2.
For additional information, please visit the ERISA
Filing website.
Blue Cross will begin assessing
an interest charge on accounts with past-due balances, starting March 2010. It
is being implemented to encourage accounts to pay their invoices on time.
All accounts will receive a notice of this change along with their invoices.
The notice will also provide fully insured accounts instructions on setting up
electronic billing.
What you need to know: - Accounts
with past-due balances 10 days after the due date may be subject to an interest
charge, effective March 1, 2010. Interest will be calculated from the due date
on unpaid balances remaining open beyond 10 days.
- Fully insured accounts
can use eBill to view their invoices or expedite their payments online.
- Although
account agreements allow Blue Cross to charge an interest rate of 1.5% per month,
the interest rate charged beginning in March 2010 will be 0.75% per month.
Tim
O'Brien/Sr. VP Sales/BCBSMA
Sincerely,
Brittany Powers
Partners Benefit Group, Inc. | 
