FAQs on the ACA and COBRA

Frequently Asked Questions

1. Did the ACA extend the COBRA premium reduction (subsidy)?

No. The ACA did not extend the eligibility time period for the COBRA premium reduction. Eligibility for the subsidy ended on May 31, 2010; however, those individuals who became eligible on or before May 31, 2010, could still receive the full 15 months as long as they remained otherwise eligible.

2. Did the ACA extend the time period individuals can have COBRA beyond 18 months?

No. The ACA did not extend the maximum time periods of continuation coverage provided by COBRA. COBRA establishes required periods of coverage for continuation health benefits. A plan, however, may provide longer periods of coverage beyond those required by COBRA. COBRA beneficiaries generally are eligible for group coverage during a maximum of 18 months for qualifying events due to employment termination or reduction of hours of work.

Certain qualifying events, or a second qualifying event during the initial period of coverage, may allow a beneficiary to receive a maximum of 36 months of coverage.

Individuals who become disabled can extend the 18 month period of continuation coverage for a qualifying event that is a termination of employment or reduction of hours. To qualify for additional months of COBRA continuation coverage, the qualified beneficiary must:

  • Have a ruling from the Social Security Administration that he or she became disabled within the first 60 days of COBRA continuation coverage (or before); and
  • Send the plan a copy of the Social Security ruling letter within 60 days of receipt, but prior to expiration of the 18-month period of coverage.

If these requirements are met, the entire family qualifies for an additional 11 months of COBRA coverage.

3. Did the ACA eliminate COBRA?

No. The ACA did not eliminate COBRA or change the COBRA rules.

4. How does the ACA affect an individual’s coverage under a group health plan?

The ACA makes many changes to employee health benefit plans. Some of the changes took effect for the first plan year that began on or after six months after enactment (Sept. 23, 2010)—so, for calendar year plans, Jan. 1, 2011. Many of the ACA’s key reforms (for example, the prohibition on pre-existing condition exclusions for all enrollees) took effect for plan years beginning on or after Jan. 1, 2014.

Source: Department of Labor

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