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

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.

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:

• Health insurance coverage is on the basis of a calendar month only. If the date of a qualifying event results in a final paycheck covering only a partial vendor payment due in the month coverage terminates, the agency must implement of the following two procedures:
  1. Obtain a cash payment from the former employee or other qualified beneficiary to complete payment for the affected month; or,

  2. Immediately cancel the former employee's or qualified beneficiary's sub-group participation and obtain a refund and/or credit from the insurer.

  The qualified beneficiary's participation through the agency group should terminate the last day of the month for which the insurer receives full payment.

• Medicare Enrollment at the time of, or subsequent to, the qualifying event no longer disqualifies an otherwise qualified beneficiary from continuation coverage under the state's plan.

3. 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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