COBRA FAQ for Qualified Beneficiaries

On Wednesday, April 29, 2020 the Employee Benefits Security Administration, Department of Labor, Internal Revenue Service, and Department of the Treasury (the “Agencies”) released a final rule (“final rule,” or “rule”) which altered and extended the timelines tied to certain benefit plans. The scope of the rule covers HIPAA, COBRA, and claim filing deadlines, and was issued as a response to COVID-19 to provide more relief to plan participant and COBRA Qualified Beneficiaries.
 
The rule defines March 1, 2020 as the first day of what the Agencies are calling the “National Emergency” period. The Agencies are then defining what they call the “Outbreak Period” as the period of time from the first day of the National Emergency until 60 days following the date that is announced as the last day of the National Emergency period. April 10, 2023, was the last day of the National Emergency. Essentially, many of the timelines tied to the COBRA election and payment process are now extended until after the Outbreak Period.

If you fall into one of the below scenarios, you will have an extended period of time to elect and/or pay your COBRA premiums. Here is an overview of those scenarios and how the timeline differs for individuals in different scenarios:

• You experienced a COBRA Qualifying Event.
  • Your election window is extended to the earlier of the following dates:
    • One year from your original due date + 60 days
    • The end of the Outbreak Period + 60 days
• You were enrolled in COBRA on or after March 1, 2020.
  • Your payment grace period is extended to the earlier of the following dates:
    • One year from your original due date + 30 days
    • The end of the Outbreak Period + 30 days
• You have been deemed disabled by the Social Security office.
  • Your window to submit your determination letter is extended to the earlier of the following dates:
    • One year from your original due date + 60 days
    • The end of the Outbreak Period + 60 days

You can contact the Sentinel Service Center by calling (888) 762-6088 to discuss the options available to you.  Representatives are available from 8:00am – 6:00pm, Monday through Friday.