COVID-19 Relief Rule Extends Some Health Enrollment Deadlines
Since the onset of the COVID-19 pandemic, some of the rules surrounding your health enrollment and coverage may have changed.
Passed on May 5, 2020, the COVID-19 Relief Rule aims to provide health coverage relief. For CalPERS members like you, this may mean extended health enrollment periods and/or coverage.
Specifically, the 60-day limitations for Special Enrollment Periods and COBRA elections are being waived during the national emergency period for those qualifying events that occurred after March 1, 2020.
The Rule will be in effect from March 1, 2020, until 60 days after the announced end of the national emergency. Upon the announced end of the national emergency, the timelines will revert to the applicable timelines associated with each qualifying event.
Special Enrollment Periods
Typically, a special enrollment period (SEP) is a 60-day period for members to notify CalPERS of a specific qualifying event.
The COVID-19 Relief Rule is focused on the following SEP qualifying events:
- New enrollment due to loss of other coverage;
- Adding a dependent due to marriage, birth, adoption, or placement for adoption; and
- Loss of coverage under a state Children’s Health Insurance Program (CHIP) or Medicaid for employees and their dependents who are eligible to receive premium assistance under those programs.
The 60-day limitations for SEPs are being waived during the national emergency period for those qualifying events that occurred after March 1, 2020.
Note: This Rule does not impact other types of enrollments, including, but not limited to, Parent-Child Relationships, Dependent Eligibility Verifications, Disabled Dependent Enrollments, and health plan change requests. These enrollment types are not covered under HIPAA, therefore they are not subject to the COVID-19 Relief Rule.
Typically, you have a 60-day window to elect continued health coverage through COBRA. The COVID-19 Relief Rule extends relief past the normal timeframes, allowing individual COBRA enrollment rights throughout the national emergency. However, your COBRA enrollment must be continuous from the date your coverage ended.
Your specific health plan administers the collection of COBRA premiums. Normal COBRA rules define timely payment as premiums paid within 30 days after the due date or within such longer period as applies to or under the plan.
The COVID-19 Relief Rule aims to prevent individual health cancellations due to late or non-payment and has extended the timely collection of COBRA premiums to 90 days after the national emergency is declared over.
- Special Enrollment Periods: members have the option to enroll and/or add a dependent on a current or retroactive basis.
- COBRA enrollments require continuous coverage. The effective date would be retroactive to the cancelation date.
If CalPERS determines you are unable to produce a marriage certificate or domestic partnership registration due to extenuating circumstances, you may execute and submit a signed and notarized CalPERS Affidavit of Marriage/Domestic Partnership (PDF).
Additionally, if you are unable to obtain a government-issued birth certificate for a dependent child due to COVID-19, you may provide a hospital birth record to facilitate the enrollment and provide the government-issued birth certificate once it is available.
Extensions for Benefit Claims and Appeals
The COVID-19 Relief Rule extended the filing timeframes through 60 days after the announced end of the national emergency:
- Claims for benefit payment (generally limited to 15 months from the date of service, prior to the COVID-19 Relief Rule)
- Health plan appeal (generally limited to 180 days from the date of the adverse benefit decision)
- External independent medical review (generally limited to four months from the date the health plan issued its appeal denial)
Governor Gavin Newsom also issued an executive order, extending CalPERS Administrative Review (AR) and Administrative Hearing (AH) requests by an additional 60 days.