Tuesday, August 30, 2011

Transitioning from COBRA to HIRSP:

Some individuals are left with no options for health insurance coverage once their COBRA continuation coverage ends. Transitioning from COBRA coverage-after the 18 months of continuing coverage ends-to the Health Insurance Risk Sharing Plan (HIRSP) may be a good option for an individual with pre-existing conditions. There is one common barrier to quickly and efficiently enrolling in HIRSP, however: obtaining a letter of creditable coverage (proof they were in a group health insurance plan) in a reasonable amount of time. HIRSP asks applicants to verify that they lost their employer-offered group health insurance.
HIRSP requires the applicant to provide a certificate of creditable coverage from past insurers or employers as proof. In some cases, HIRSP will accept other forms of proof of coverage, but this may take longer as individuals at HIRSP will have to verify all the information. Before we get too detailed, recall the following background information on COBRA:
The Consolidated Omnibus Budget Reconciliation Act (COBRA) gives workers and their families who lose their health benefits the right to choose to continue group health benefits provided by their group health plan for limited periods of time under certain circumstances such as voluntary or involuntary job loss, reduction in the hours worked, transition between jobs, death, divorce, and other life events. Qualified individuals may be required to pay the entire premium for coverage up to 102 percent of the cost to the plan.
Now, reconcile this coverage option of limited term with the option of applying for HIRSP. If you are applying for HIRSP because you lost your employer-offered group health insurance, you are required to meet all of the following requirements:
  • You lost your employer-offered group health insurance. As documentation, you are required to provide HIRSP with a certificate of creditable coverage from past insurers or employers or other forms of proof of coverage which HIRSP will verify (e.g. explanation of benefits, health insurance ID card(s))
  • You did not voluntarily cancel your coverage
  • You exhausted your continuation coverage under your employer-offered group health insurance, including state continuation coverage or Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage, if offered. (If you elected COBRA, but found it was more expensive than HIRSP, you can enroll in HIRSP but will be subject to the 6 month waiting period for coverage of pre-existing conditions. There is no wait if your COBRA is exhausted.)
  • Including this employer-offered group health insurance, you have had continuous insurance coverage for at least 18 months with no gap in coverage greater than 63 days
  • You applied to HIRSP within 63 days of losing your employer-offered group health insurance, including COBRA if offered
  • You are not eligible for Medicare
Consider again the transition from COBRA to HIRSP. The HIRSP Authority needs a creditable coverage letter in order to finalize an application and provide an effective date. Often, an insurance carrier or former employer will need to be reminded to provide the letter as soon as possible. A letter is sometimes easier to remember if you are transitioning to HIRSP immediately after losing your employment and employer-sponsored insurance. It's harder to remember after taking advantage of 18 additional months of COBRA coverage. HIRSP will give applicants a 10-day buffer after their requested effective date to supply their letter. If needed, HIRSP will go so far as to call the former employer to verify dates of coverage.

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