Q.- A COBRA continuant did not pay all of the premium for October. She is now telling us that she was short on funds and wants to pay the premium to have October coverage. Do we have to let her pay now?
A.- No. We assume payment was due on the first of the month for coverage for that month. If that is the case, payment was due October 1, but the plan had to give her a 30 day grace period to make her payment. Now that it is after the 30 day grace period, you do not have to grant her appeal. If you are considering allowing her to pay now, you should confirm that your insurance company will allow the reinstatement. You should also keep in mind that you should treat all future appeals similarly to how you treat this appeal.