On May 20, 2021, Commissioner Afable issued a bulletin informing insurers in the state of the premium subsidy requirements under the ARPA. The bulletin also announces that forms specific to the state’s healthcare continuation requirements are available.
The ARPA provided a 100% subsidy for federal COBRA and state healthcare premiums for a period from April 1, 2021, to September 30, 2021. The ARPA also required certain notices and forms be distributed to all persons who may qualify for the subsidy; namely, those individuals who either experienced a reduction in hours (voluntary and involuntary) or were involuntarily terminated and are not eligible for other group health plan coverage or Medicare.
The commissioner stated that the state will enforce the requirement that the insurer treat premium assistance eligible individuals as having paid their premium in full. This requirement applies to eligible employees and dependents covered by an insured group health plan subject solely to Wisconsin continuation law. Additionally, if an employer or employee paid or pays continuation premium on or after April 1 on behalf of an assistance eligible individual, the state requires the insurer to refund that premium amount in full by the later of 30-days from the date of this bulletin or receipt of the payment. Finally, the state will not enforce the requirement under Wis. Stat. § 632.897 (8), that the premium be paid by the employee, to simplify the process for an insurer to qualify for the tax credit.
The bulletin also states that employers that are subject to Wisconsin's continuation law must provide the Model ARPA notice for state continuation developed by the US Department of Labor. The state has its own versions of these notices, which apply the state’s healthcare continuation law, and can be found here. Under the state’s healthcare continuation law, a person covered by a healthcare plan regulated by the state can elect to continue that coverage for up to 18 months when that person would lose that coverage for specific qualifying reasons, including involuntarily termination and reduction of hours.
Employers who are fully insured by policies regulated by the state should be aware of this information.
Bulletin 20210520 »
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