2009-08-18
Hewitt Associates submitted comments to the U.S. Department of Labor's Employee Benefits Security Administration (EBSA) on August 13, 2009 concerning the expedited review of COBRA premium subsidy denials.
As background, COBRA premium subsidies are available to certain involuntarily terminated employees under provisions included in the American Recovery and Reinvestment Act of 2009 (P.L. 111-5). Individuals can file an appeal with the Department of Labor (DOL) if they believe they qualify for the COBRA premium subsidy but were subsequently denied; the DOL then has 15 business days to review the appeal.
In the comment letter, Hewitt outlines concerns pertaining to the following issues:
- Time to Respond, including:
- Delivery to appropriate contacts when an employer uses a third-party administrator; and
- Adequate time for an employer to research an individual's claim.
- Review of the Facts, including employer access to the individual's application for review.
- Procedures Upon Approval, including clarification as to when benefits should take effect for approved claims.
The Hewitt comment letter linked to at right, authored by Molly Iacovoni, HM Legal, Alison Schaap, HM Legal, and Matt Chango, HRO Benefits Delivery, discusses Hewitt's concerns and suggestions in further detail.
For additional information on the COBRA premium subsidy, visit Resources: COBRA Provisions Under ARRA.
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