This process should only be followed when an AEI elects state continuation during the subsidy period. If the member is not currently covered under state continuation, the employer will also need to supply the standard enrollment form in addition to the forms below.
The steps below are only for processing individuals who qualify for the ARPA COBRA premium subsidy (includes new and existing state continuation members) for whom EmblemHealth bills the group directly. Follow the standard process for enrolling individuals in state continuation who are not eligible for the subsidy (e.g., individuals who terminate employment voluntarily).
1. The employer group must send each identified individual the applicable model notice and Summary of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021. These notices are on the U.S. Department of Labor’s COBRA Premium Subsidy page. They contain important information required for accurate processing and record keeping.
2. Individuals will need to review the subsidy information contained in the notice, and if eligible for the subsidy, complete the COBRA/Continuation Coverage Election Form and Request for Treatment as an Assistance Eligible Individual and return these forms to the employer.
3. The employer group or broker must send the completed documents listed below for each subscriber eligible for the COBRA premium subsidy as an AEI to EmblemHealth account services. This includes employer groups working with a third-party administrator. These notices are on the U.S. Department of Labor’s COBRA Premium Subsidy page.
· COBRA/Continuation Coverage Election Form (included within model notice)
· Request for Treatment as an Assistance Eligible Individual. (included within Summary of the COBRA Premium Assistance Provisions under the ARPA of 2021 notice)
Be sure to write the participant’s SSN, DOB, subsidy start and stop dates, and the EmblemHealth group number onto this document to ensure proper processing.
4. EmblemHealth will process these COBRA premium subsidy state continuation enrollments and handle the related billing as follows for direct bill to employer groups with 19 and under full-time eligible employees:
For subscribers who are eligible for the COBRA premium subsidy and normally direct billed to the employer group EmblemHealth will exclude those AEIs from the employer group’s invoice during the subsidy period. This is because EmblemHealth will pay the premium up front during the AEI’s subsidy period (as EmblemHealth will be responsible for filing for a federal tax credit). Once the subsidy period is over and if the individual is still eligible for state continuation coverage, the individual will be placed back on the invoice for the group to continue the premium payments.
Employer groups that have already paid their premiums to EmblemHealth during the subsidy period for Assistance Eligible Individuals (AEIs), will have their premiums refunded by EmblemHealth.