Hogan Knows

CTContinuationofcoverage.pdf (266 KB)

Please see the newly issued continuation of coverage requirements issued from the Insurance Commissioner’s office. Employers already have an obligation to administer the cumbersome requirements of the TARP COBRA subsidy and must now administer 30 months of continuation for their severed employees. This is almost certainly a sign of things to come as the government imposes additional administrative burdens upon employer groups.

The Governor signed the above Act into law on May 5, 2010, and the Act is effective May 5, 2010.The law now permits employees/group certificate-holders who lose coverage under Connecticut fully insured small employer and large employer group health insurance policies to elect continuation of coverage for up to 30 months, in the event of layoff, reduction of hours, leave of absence, or termination of employment, except in the event of death of the employee or termination of employment due to gross misconduct. Previously Connecticut had followed the federal rule of 18 months for these events.

The law applies to former employees covered under Connecticut fully insured small employer and large employer group health insurance policies who are currently on state or federal (COBRA) continuation as well as individuals who elect continuation coverage on or after May 5, 2010, due to one of the qualifying events described in the preceding paragraph. As an example, if a former employee is in the middle of a current 18 month continuation period, that individual now is eligible for continuation of an additional 12 months for a total of 30 months (provided the individual pays premium on a timely basis and does not become eligible for other group health insurance).