Q.- An employee was involuntarily terminated in 2019 and elected COBRA. He dropped our coverage when he got a new job. We sent him a second-chance election form at the end of May informing him about the premium subsidy. He just quit the job he had and now wants free health coverage from us. Do we still have to give him subsidized COBRA coverage?
A.- Maybe not, depending on when the letter informing him of a second-chance to elect subsidized coverage was mailed to him. You were correct to give an involuntarily terminated employee another chance to elect COBRA coverage with the ARPA premium subsidy. The second chance election lasted only 60 days from the date of the notice. If notice was mailed to the former employee before the May 31, 2021 due date, his 60 days to elect coverage would have expired July 31, 2021. Check the timing of when the notice was sent to determine if he still is able to elect subsidized coverage under your plan.
