In March 2020, the Department of Labor (DOL), together with the Department of Treasury and the Internal Revenue Service (IRS) (collectively “Agencies”), issued final rules and, in February 2021 and July 2021 subsequent guidance with respect to the extension of certain time frames for employee benefit plans, participants and beneficiaries affected by the COVID-19 outbreak period (“Agencies Guidance”). As a result, COBRA Qualified Beneficiaries (QBs) were permitted to continue plan coverage if the COBRA payment deadline (either for the initial payment or any subsequent payment) was required to be disregarded by the Agencies Guidance, regardless of whether or not an initial COBRA premium payment or subsequent premium payments were made.
Beginning July 1, 2022, COBRA Terminations for Non-Payment of Premiums will Resume. Any QBs that have failed to make timely COBRA premium payments, will receive notice of termination of plan coverage for non-payment of COBRA premiums retroactively back to the last date full payment was received. However, plan coverage will be reinstated if premium payments (including any retroactive payments) are received within the earlier of (1) 30 days immediately following the 12-month period beginning with the date the QB was eligible for relief under the Agencies Guidance; or (2) 60 days after the end of the announced COVID-19 National Emergency.
Groups that do not have LBS as their COBRA Administrator and who bill their own COBRA will need to send us a request to terminate. Documentation verifying the termination date may be required.
Please contact your account representative with questions.