ARRA Premium Reduction for Continuation Coverage – Model Notices for Insurers
Pursuant to the American Recovery and Reinvestment Act of 2009 (ARRA) and a related State law signed by the Governor on June 18, 2009 (P.A. 96-0013), insurers and HMOs are required to notify certain individuals about the availability of premium reductions for group continuation coverage provided for under ARRA. For more detailed information about these laws, please see the Department’s fact sheet entitled “Federal Stimulus – Premium Reduction for Group Continuation Coverage.”
The U.S. Department of Labor published model notices to help employers and insurers comply with ARRA’s notification requirements. The Illinois Department of Insurance has modified these notices to account for features unique to Illinois continuation law.
Together, ARRA and P.A. 96-0013 require insurers and HMOs to provide notice to three distinct groups of qualified beneficiaries whose group coverage is subject only to State continuation law [215 ILCS 5/367e or 215 ILCS 125/4-9.2]:
- Individuals who lose group coverage due to a termination of employment or a reduction in hours below the minimum required by the group plan that occurs between June 18, 2009, and December 31, 2009.
- Insurers can use Model Notice 4a or Model Notice 4b to comply with the notice requirements applicable for this group of individuals.
- The longer Notice 4a contains all of the information related to the premium reduction and other rights and obligations under ARRA, as well as all of the information necessary for the individual to make an election of continuation pursuant to the State continuation law.
- Notice must be sent within 10 days of the termination of employment or the reduction in hours below the minimum required by the group plan.
- Individuals who lost group coverage due to a termination of employment or a reduction in hours below the minimum required by the group plan that occurred between September 1, 2008, and June 18, 2009, and who had an election of continuation coverage in effect as of June 18, 2009.
- Insurers can use Model Notice 4b to comply with the notice requirements applicable for this group of individuals.
- Notice must be sent to these individuals by July 2, 2009.
-
Individuals who lost group coverage due to an involuntary termination of employment that occurred between September 1, 2008, and June 18, 2009, and who did not have an election of continuation coverage in effect as of June 18, 2009.
- Insurers can use Model Notice 9 to comply with the notice requirements applicable for this group of individuals. Such notice must contain information related to the premium reduction and other rights and obligations under ARRA, as well as all of the information necessary for the individual to make an election of continuation pursuant to paragraph 9 of 215 ILCS 5/367e or of 215 ILCS 125/4-9.2.
- Notice must be sent to these individuals by July 18, 2009.
Insurers and HMOs may use notices that differ from the model notices provided by the Department. However, all notices must conform to all applicable requirements set forth in Section 3001 (a)(7) of Title III of Division B of the federal American Recovery and Reinvestment Act of 2009.
|
