Please be aware that employees on a temporary leave of absence or temporary layoff have different rules affecting their coverage and reinstatement of coverage than employees that have been terminated.
Condensed from CHSIC PPO Group Certificate of Coverage: Section 9 pages 40-41*:
*An employee will be deemed Actively at Work if the Employee is on a leave of absence or temporary layoff, for reasons other than Disability, for a period exceeding the end of the policy month following the policy month during which the leave of absence or layoff commences.
Example: Employee is laid off or asked to not show up to work on 3.26.20. The employee will have coverage (barring employer terming group or employee coverage or not paying premium) until the end of the following month – in this case 4.30.20. The employee would be eligible for COBRA on 5.1.20.
Please refer to the plan document applicable to your policy to verify this coverage. Other CHP coverage documents include:
- CHSIC EPO Group: Section 9 pages 46-47
- CHSIC SMGRP: Section 9 pages 47-48
- Level Solutions: Section 10 page 66
Rehiring Terminated Employees:
The enrollment waiting period for rehires can be dependent on the amount of time from termination or break in coverage to rehire date and the size of the group.
All groups: If an employee has less than 31 days break in coverage, we will reinstate them without a break of coverage. This is dependent on the group allowing no break in coverage. The group must apply the rule uniformly to all members – they cannot force a break in coverage for an hourly employee but not enforce a break in coverage for salary employees.
Groups 50+: If the break in coverage is less than 13 weeks we would follow the ACA rules and not apply a waiting period.
Small groups 2 – 50: We allow the group to determine if a waiting period applies to a rehire within 6 months of the termination date. The group must indicate the policy they will follow. The group must apply the rule uniformly to all members – they cannot force a waiting period for an hourly employee but not enforce the waiting period for a salary employee.
COBRA Eligibility
If the employee is still eligible for coverage and waiving coverage for their dependents, the dependents would not be eligible for COBRA. If the employee has a reduction in hours and no longer meets the eligibility requirements then that would be a COBRA event for themselves/dependents.