Last week, the New Jersey Department of Banking and Insurance (DOBI) released Bulletin No. 21-08 requiring plans following NJ state continuation to offer the American Rescue Plan Act (ARPA) COBRA premium subsidy to additional individuals. A copy of the NJ rule may be accessed by clicking here.
The Bulletin requires plans subject to NJ state continuation to offer a second-chance continuation of coverage election with the ARPA premium subsidy to individuals who had a qualifying event of reduction in hours or involuntary termination of employment and either elected NJ state continuation coverage and terminated coverage or never elected coverage and would still be in their 18-month continuation period. The second-chance election must be given to individuals who had a qualifying event of reduction in hours/involuntary termination of employment back to November 1, 2019.
If you use BAS’ Cobra Control Services for your COBRA administration, CCS will send the required notices on your behalf if you have identified your continuation of coverage population’s qualifying events as a voluntary or involuntary termination of employment in MyEnroll360. Please contact service@CobraControl.com if you are uncertain if you have made the required designations in MyEnroll360.