[MyOEBB] FW: Email going to OEBB Entities - COBRA Subsidy Invoice Process

[MyOEBB system updates]

Dear OEBB Benefits Administrators, Business Managers, and Premium Contacts -

On April 30, we sent you an email describing the new COBRA subsidy required by the American Rescue Plan Act (ARP). That message described how we will determine who will be eligible for this employer-paid subsidy. We have pasted a copy of that email at the bottom of this message. We have also attached an Eligibility Guide to help you figure out what should be labeled "voluntary" or "involuntary" for this process.

As promised in our earlier message, we have now defined

THE INVOICE AND BILLING PROCESS:

  *   PEBB will distribute invoices and collect premiums on behalf of BHS. This avoids the need for individual contracts between BHS and each employer.
  *   Members who meet the eligibility requirements (described in our previous email and pasted below) are eligible for the COBRA subsidy program.
  *   BHS will enroll eligible beneficiaries (and their dependents, as applicable) retroactively effective April 1, 2021.
  *   BHS will send OEBB monthly invoices for the eligible member/dependent(s).
  *   OEBB will distribute the invoices to the appropriate employers.
  *   Each employer will send the premium (payment) to OEBB. It's very important that the payment be sent timely, within 10-15 days of the receipt of the invoice.
  *   OEBB will send BHS the premium received from each employer.
  *   BHS will forward premiums to the appropriate health plan carriers.

YOUR ACTION REQUIRED:
We need to know who will serve as your point-of-contact for invoices and payment questions. Please send the name and email for your primary invoice point-of-contact to Rosie Chernishoff at Rosie.CHERNISHOFF at dhsoha.state.or.us<mailto:Rosie.CHERNISHOFF at dhsoha.state.or.us> no later than Friday, May 14, 2021.

Thank you, again, for your patience as we work through compliance with this law. As we said earlier, our number one goal is to create a simple process with the least amount of additional work for you.

If you have any questions regarding the financial process, please contact Rosie Chernishoff at rosie.chernishoff at dhsoha.state.or.us<mailto:rosie.chernishoff at dhsoha.state.or.us>.

Regards,

Ali Hassoun
Director
Oregon Educators Benefit Board / Public Employees' Benefit Board
Oregon Health Authority - Health Policy & Analytics


REFERENCE COPY OF APRIL 30 MESSAGE BELOW:

Dear OEBB Benefits Administrators, Business Managers, and Premium Contacts -

The American Rescue Plan Act of 2021 (ARP) was signed on March 11, 2021. This new federal law subsidizes the full COBRA premium for "Assistance Eligible Individuals" (AEI). This premium assistance is available April 1, 2021 through September 30, 2021.

An AEI qualifies for COBRA premium assistance if they:

  *   lose benefits due to an involuntary employment termination or work hours reduction, AND
  *   are not eligible for other group health coverage (a new employer or spouse's employer plan), AND
  *   are not eligible for Medicare, AND
  *   are eligible and elect COBRA during the subsidy period.

Employers are responsible for paying 100 percent of an AEI's COBRA premium during the subsidy period (April 1, 2021 through September 30, 2021). You will be reimbursed by the federal government through:

  *   a credit against payroll taxes, and (if applicable)
  *   an overpayment refund for credit amounts exceeding payroll taxes.

Employers that don't satisfy COBRA continuation coverage requirements may be investigated by the Department of Labor. They may also be subject to an excise tax under the Internal Revenue Code.

OEBB currently contracts with BenefitHelp Solutions (BHS) for our COBRA needs.  Together we have developed the following process to determine subsidy eligibility:

  *   BHS will send legally required COBRA notices to all current COBRA members and those newly eligible, no later than May 31, 2021.
  *   BHS will also send an attestation form. This form outlines the subsidy eligibility requirements. The beneficiary will need to sign and date the form attesting that they are eligible for the subsidy program if they wish to enroll.
  *   BHS will send OEBB a weekly list of members who wish to enroll and have attested they are eligible for the subsidy. We will send you your list of members, asking you to note their termination reasons (involuntary, voluntary, or reduction in hours) and return your list to OEBB.
  *   OEBB will send the lists to BHS.
  *   BHS will enroll those you have confirmed as eligible (referred to as "eligible beneficiaries") into the COBRA subsidy program.
  *   BHS will enroll eligible beneficiaries (and their dependents, as applicable) retroactively effective April 1, 2021.

This completes the first part of the process. We are currently working out the invoice and billing process.  We will provide those details once we have a solution in place.

Thank you for your patience as we work through compliance with this law. Our number one goal is to create a simple process with the least amount of additional work for you.

If you have questions about:

  *   eligibility for the subsidy, please call BHS at 1-800-556-2230.
  *   the process, please email Sheila Clausen, OEBB/PEBB Policy Analyst at: SHEILA.C.CLAUSEN at dhsoha.state.or.us<mailto:SHEILA.C.CLAUSEN at dhsoha.state.or.us>.

Regards,
Ali Hassoun
Director
Oregon Educators Benefit Board / Public Employees' Benefit Board
Oregon Health Authority - Health Policy & Analytics






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