COMPTROLLER'S SEAL STATE OF CONNECTICUT
STATE OF CONNECTICUT
NANCY WYMAN
COMPTROLLER
OFFICE OF THE STATE COMPTROLLER
55 ELM STREET
HARTFORD, CONNECTICUT 06106-1775
MARK OJAKIAN
DEPUTY COMPTROLLER

MEMORANDUM NO. 95 - 3

FEBRUARY 1, 1995

TO THE HEADS OF ALL STATE AGENCIES

ATTENTION: Personnel and Payroll Officers
SUBJECT: Continuation Medical and Dental Coverage
  1. BACKGROUND
    Since January 1, 1987, employees and eligible dependents have been offered the opportunity to continue medical and/or dental insurance in effect at the time one of several "qualifying events" occur. The federal law governing continuation coverage, known by the acronym COBRA, has undergone certain revisions since the original enabling legislation was passed in 1986. Additionally, state law and policy have acted in certain instances to increase those minimum benefits provided by federal law. Accordingly, the purpose of this memorandum is to update all agencies on current state policy affecting eligibility for continuation coverage in its health insurance plans.

  2. DISCUSSION
    Duration of continuation coverage is based on the type of qualifying event which triggers the entitlement to this benefit.

    The following chart indicates the various qualifying events, the qualified beneficiary (ies), and the period of time for which coverage can be continued.

QUALIFYING EVENTQUALIFIED BENEFICIARYLENGTH OF COVERAGE
Terminated Employee Enrolled Employee and/or
Enrolled Dependents
24 Months
Employee Laid Off or Whose Hours Have Been Reduced Enrolled Employee and/or Enrollment Dependents 24 Months
Leave-of-Absence Without Pay Enrolled Employee and/or Enrollment Dependents 24 Months
Termination, Layoff or Reduction in Hours Enrolled Employee and/or Enrollment Dependents Disabled According to Social Security 29 Months
Death of Employee or RetireeEnrolled Dependents of Decedent36 Months
Divorce or Legal SeparationEnrolled Divorced/Legally Separated Spouse and/or Other Eligible Dependents 36 Months
Dependent Child No Longer Qualifying as DependentEnrolled Dependent Child 36 Months

Except in the case of the employee's death, coverage through the state group remains in effect for the qualified beneficiary until the first day of the second month following the qualifying event, at which time through the state group ends the last day of the month an employee becomes deceased.

Under the law, the employee, spouse, or other family member has the responsibility to inform the employing agency personnel or payroll officer of a divorce, legal separation or a child losing dependent status under state-sponsored coverage.

In the case of family or medical leave from employment pursuant to section 5-248a C.G.S., the employee and covered dependents can remain on the agency's group. The employee is obligated to pay directly to the agency his or her share of any insurance premium due; the agency will continue to pay for its share of the premium. At the expiration of such leave, the employee has the option of continuation coverage for an additional 24 month period under COBRA by paying 102% of the group rate.

For any other leave of absence without pay, during the first four months the employee is eligible to remain on the agency's group provided he or she pays the full premium for the insurance. If the leave extends beyond four months, the employee has the option of continuation coverage for an additional 24 months under COBRA by paying 102% of the group rate.

Notification:
New Employee: All new employees must be notified to their eligibility for continuation coverage in conjunction with the hiring process. The attached notice must be distributed to the new employee as part of orientation.

Notification Form:
A revised CO-1022 "Group Health Insurance Continuation Coverage Election" is attached to this memorandum. It should be used in connection with all coverages except CIGNA dental insurance for which a CO-1022-1 (also attached) is completed. Be sure to provide all pertinent information in Section 1 of the election form prior to issuing it to the qualified beneficiary.

Qualifying Event: The qualified beneficiary (s) must be informed of their right to continuation coverage within 14 days of the qualifying event. If the qualifying event is a termination of employment, notice should be given at the time of the exit interview, if one occurs. If there is no qualifying events, notice should be mailed to the last known address of the qualified beneficiary. A copy of the notice and a record of its mailing should be retained by the agency. Agencies should discontinue the practice of forwarding a copy of the notice to the Benefits Division.

Election: The qualified beneficiary must elect continuation coverage within 60 days of the date coverage would otherwise terminate through the agency group, or the date of the agency notice informing him or her of eligibility for continuation coverage, whichever occurs later. Unless otherwise requested, election to continue coverage will be deemed to include an election on behalf of all qualified beneficiaries included on the contract who would otherwise lose such coverage because of the qualifying event.

Premium Payment: The qualified beneficiary will be billed directly by the COBRA Administrator or, in the case of CIGNA dental insurance, directly by the insurer.

Miscellaneous:

  1. Conclusion

    Revised Forms CO-1022 and CO-1022-1 should be available for order in approximately three months. In the interim, please use duplicates of the attachments to this memorandum.

    All questions or requests for assistance should be directed to the Comptroller's Benefits Division, Research and Analysis Unit, at 566-1831.

Nancy Wyman
State Comptroller

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