[MyOEBB] OEBB to Implement Federal Rescission Reforms on October 1, 2010

[MyOEBB system updates]

no, I am turning in circles!!

On 11/2/2010 2:56 PM, MyOEBB system updates wrote:
>
> Was I suppose to receive this?
>
> Linda Tibbles
>
> Employee Benefits Specialist
>
> Hillsboro School District
>
> 3083 NE 49th Pl #104
>
> Hillsboro, OR 97124
>
> Phone: 503-844-1518
>
> Fax: 503-844-1710
>
> /Ensure a sustainable future - only print when necessary./
>
> *From:*myoebb-bounces at listsmart.osl.state.or.us 
> [mailto:myoebb-bounces at listsmart.osl.state.or.us] *On Behalf Of 
> *MyOEBB system updates
> *Sent:* Tuesday, November 02, 2010 2:22 PM
> *To:* MyOEBB system updates
> *Subject:* Re: [MyOEBB] OEBB to Implement Federal Rescission Reforms 
> on October 1, 2010
>
> I have gone in and put calendar reminders on the 15th of each month we 
> have a termination for the 10-11 year.  So far I only have retirees 
> that turn 65 and Tami Bonney.  I will do my _best_ to stay ahead of it.
>
> On 9/30/2010 4:57 PM, MyOEBB system updates wrote:
>
> */_Federal Health Care Reform -- Rescission of Coverage_/*
>
> As you may have already heard, the federal health care reform bill 
> enacted new restrictions on an Employers' rescission of coverage. OEBB 
> will implement the new restrictions effective */_October 1, 2010_/*.
>
> Rescission of coverage can simply be defined as:  The _retroactive 
> cancellation_ of a health insurance policy.
>
> Under the new restrictions, a rescission (retroactive cancellation) by 
> the Employer is illegal _except_ in cases of fraud or intentional 
> misrepresentation of material fact as prohibited by the terms of the 
> plan or coverage. Please read this entire e-mail.  It explains how 
> this change */_will_/* affect your educational entity and members.  I 
> also encourage your educational entity benefits team to participate in 
> one of the phone conferences listed below.
>
> */_Grandfathering Medical Plans_/*
>
> OEBB will not grandfather any plans currently available.  This means 
> the Rescission of Coverage will apply to all OEBB plans and that 
> overage dependents age 19 through 25 may be enrolled regardless of 
> whether they are eligible for or have other group coverage.
>
> */_QSC Changes_/*
>
> Effective October 1, 2010, OEBB will limit QSC date ranges in MyOEBB.  
> You will not be able to back date any coverage termination date; you 
> will only be able to go forward.  This means you will not be able to 
> access a 60-day retro feature as you have in the past.  If you need to 
> retro adjust someone's enrollment due to intentional 
> misrepresentation, you will need to contact OEBB for assistance.
>
> */_Invoicing Changes_/*
>
> Effective October 1, 2010, the following invoicing rules will apply 
> due to rescission:
>
> */_Active Employees_/*
>
>     * If the *_Educational Entity fails to notify OEBB_* of a
>       retroactive employee termination, coverage must end on the last
>       day of the current month. *_No retroactive terminations_ or
>       adjustments can be allowed.
>     * If the *_Active Eligible Employee fails to notify their
>       Educational Entity_* within 31 days in the event their spouse,
>       domestic partner or other dependent no longer meets eligibility
>       criteria, the affected individual's coverage will be
>       retroactively terminated to the end of the month in which
>       eligibility was lost.  OEBB considers this to be intentional
>       misrepresentation and grounds for retroactive termination of
>       coverage. *_Credits for retroactive adjustments will be issued_
>       to the Entity for up to 90 days.
>     * If the *_Active Eligible Employee notifies the Educational
>       Entity within 31 days after an event_* terminating eligibility
>       of the employee's spouse, domestic partner or other dependent,
>       coverage for the affected individual will end on the last day of
>       the month in which OEBB receives notification of the event from
>       the Educational Entity.  *_No retroactive terminations or
>       adjustments_ are allowed.
>
> */_Retirees (Self-Pays)_/*
>
>     * OEBB *_can retroactively terminate coverage in the case of
>       non-payment_*_._ Retroactive terminations for failure to pay
>       premiums or contributions are not rescissions.  Coverage will be
>       terminated on the last day of the month for which premiums were
>       paid in full by the retiree to the Entity and credits for
>       retroactive adjustments will be issued to the Entity for up to
>       90 days.
>     * The *_retiree is responsible for reporting to their Educational
>       Entity within 31 days of the date he/she or a dependent becomes
>       eligible for Medicare_* coverage due to a disability. _Failure
>       to report_ this loss of eligibility within 31 days is considered
>       by OEBB to be intentional misrepresentation and grounds for
>       retroactive termination of the affected individual's coverage
>       back to the last day of the month prior to the Medicare
>       effective date.
>     * OEBB automatically terminates coverage for early retirees who
>       become eligible for Medicare due to age.
>
> *//*
>
> */_OEBB to Provide Statewide Question & Answer Phone Conferences_/*
>
> OEBB has scheduled several statewide phone conferences (listed below) 
> to discuss federal health care reform, rescission of coverage, overage 
> dependent children, and the post Open Enrollment Mail Out.
>
> Monday, October 4^th -- 2:00 to 3:30 PST
>
> Tuesday, October 5^th -- 2:00 to 3:30 PST
>
> Wednesday, October 6^th -- 11:00 to 12:30 PST
>
> Thursday, October 7^th -- 3:30 to 5:00 PST
>
> If you would like to participate in one of the above calls, please 
> call 503-378-2167 using code 31381.
>
> */_Scenarios_/*
>
> *Scenario*
>
> 	
>
> *Rescind coverage?*
>
> 	
>
> *What does this mean for my educational entity?*
>
> */Employment Termination/*
>
> In the event an educational entity does not enter the termination of 
> coverage timely due to lost paperwork, untimely reconciliation, or 
> other administrative reasons.
>
> 	
>
> No, this can't be considered intentional misrepresentation and thus is 
> not grounds for rescission.  The employer was aware of the change and 
> the terminated employee didn't misrepresent anything. The termination 
> of benefits in the MyOEBB system is the responsibility of the 
> educational entity.
>
> Coverage must end on the last day of the current month. No retroactive 
> terminations or adjustments can be made.
>
> 	
>
> This means when the educational entity discovers the error in MyOEBB 
> they will only be able to terminate coverage in MyOEBB at the end of 
> the month of discovery.  There will be no retro terminations allowed 
> or credits available for the educational entity.  The terminated 
> employee will have these extra months of benefit coverage.
>
> */Qualified Status Changes -- Death, Divorce, dropping Domestic 
> Partner, child ceasing to meet eligibility and, on retiree plans, 
> gaining of Medicare./*
>
> //
>
> In the event a member (this applies to self-pay and partial self-pay 
> groups also) experiences a qualified status change or, on a retiree 
> plan, gains Medicare and fails to notify their educational entity 
> within the timeframe specified in our administrative rules.
>
> 	
>
> Yes, this can be considered intentional misrepresentation only if OEBB 
> takes the following action steps to notify educational entities and 
> members that failure to take action in these types of scenarios is 
> considered intentional misrepresentation.
>
> These terminations dates would need to be effective at the end of the 
> current month or the month the QSC is occurring the member fails to 
> notify the educational entity of the QSC event within the timeframe 
> specified in the OEBB administrative rules.
>
> Only if the member fails to report this timely can we rescind coverage.
>
> 	
>
> If the member _did not_ report this change timely it will be 
> considered misrepresentation.  When an eligibility or enrollment 
> violation has been discovered and investigated, OEBB will notify the 
> member and the Educational Entity of the outcome*. *If the outcome 
> includes rescission of coverage, OEBB will give a 30-day notice of 
> such rescission prior to terminating the affected individual's 
> coverage retroactively to the date the affected individual was no 
> longer eligible for benefits.The notice will include the specific 
> reason(s) for the decision, a reference to the specific plan provision 
> or OAR on which the determination was based, a description of any 
> additional information required and a description of the OEBB appeals 
> process, as the member has the right to appeal the decision through OEBB.
>
> The member may be responsible for any claims paid and expenses 
> incurred during the period of time the affected individual was 
> enrolled inappropriately.
>
> Policy term violations may apply to the subscriber and their dependents.
>
> There will be up to a 90-day credit available (if applicable) for the 
> educational entity.
>
> If the member _did_ report this change timely it will not be 
> considered misrepresentation but an error originating from the 
> educational entity.  This means when the educational entity discovers 
> the error in MyOEBB they will only be able to terminate the benefits 
> in MyOEBB at the end of the month of discovery.  There will be no 
> retros allowed or credits available for the educational entity.  The 
> terminated employee will have these extra months of benefit coverage.
>
> *100% /Self-pay Groups (COBRA/HB 2557/Retiree)/*
>
> //
>
> In the event a member in one of OEBB's self-pay groups stops paying 
> their premiums, coverage is terminated retroactive to the end of the 
> month that the full premium was paid.
>
> 	
>
> OEBB can retroactively terminate coverage in the case of non-payment. 
> Retroactive terminations for failure to pay premiums or contributions 
> are not rescissions.
>
> Coverage will be terminated on the last day of the month for which 
> premiums were paid in full.
>
> 	
>
> OEBB or its contractor will terminate coverage on the last day of the 
> month that premiums were paid in full.
>
> */Partial Self-pay Groups - Employees, Early retirees, or COBRA 
> participants who pay a portion of their total premium/*
>
> //
>
> When a member in a partial self-pay group fails to pay their portion 
> of the premium and the educational entity continues to "float" the 
> entire premium (pay the entire premium to OEBB) while waiting for the 
> employee, early retiree, or COBRA participant to make up their 
> portion. Once the entity notifies OEBB, we will terminate coverage 
> back to when the member stopped paying their portion and will give the 
> entity up to a 90-day credit.
>
> 	
>
> OEBB can retroactively terminate coverage in the case of non-payment 
> -- whether or not the member was responsible for the full premium or 
> partial premium. Retroactive terminations for failure to pay premiums 
> or contributions are not rescissions.
>
> Coverage will be terminated on the last day of the month for which 
> premiums were paid in full.
>
> 	
>
> This means when an educational entity discovers the non-payment they 
> will notify OEBB and provide the necessary information so OEBB can 
> terminate coverage(s) in MyOEBB at the end of the month of last full 
> payment was received.  There will be up to a 90-day credit available 
> (if applicable) for the educational entity.
>
>   
>   
> _______________________________________________
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> MyOEBB at listsmart.osl.state.or.us  <mailto:MyOEBB at listsmart.osl.state.or.us>
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> Hosted by the Oregon State Library (503)932-1004
> Please use this contact for technical list questions only.
> For informational questions related to message content, please contact the sender of the message, by phone or email.
>
>
>
> -- 
> Sheri Hatton
> Payroll Clerk
> Pleasant Hill School District
> 36386 Highway 58, Pleasant Hill OR 97455
> 541-736-0794, FAX 541-746-2537
>   
>   
>   
>
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>
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> MyOEBB at listsmart.osl.state.or.us
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> Please use this contact for technical list questions only.
> For informational questions related to message content, please contact the sender of the message, by phone or email.

-- 
Sheri Hatton
Payroll Clerk
Pleasant Hill School District
36386 Highway 58, Pleasant Hill OR 97455
541-736-0794, FAX 541-746-2537




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