COVID-19 Benefit Notifications

Under the COVID-19 National Emergency relief rules, the University and its insurance carriers will disregard days during the “Outbreak Period” (as defined below) for purposes of determining the date by which an individual (e.g., a participant, claimant, qualifying dependent, qualified beneficiary) must take the following actions:

1. Request mid-year enrollment in group health plan coverage due to a HIPAA special enrollment event.
2. Elect to initially enroll in COBRA, make an initial or subsequent COBRA premium payment, or provide a required notice of a COBRA qualifying event.
3. File an initial claim for benefits, file an internal or external appeal in response to an adverse benefit determination, or perfect a request for external appeal in response to a notice that the request is not complete.

The “Outbreak Period” is the period that begins on the date of an applicable event (the “Applicable Event Date”) and ends on the earlier of (a) one year from the “Applicable Event Date”; or (b) 60 days after the announced end of the COVID-19 National Emergency.

The COBRA relief referenced above is described in the COVID-19 Regulatory Update that is included with the COBRA election package that qualified beneficiaries are furnished at the time of a COBRA qualifying event and are not addressed here.  The summary plan description (SPD) for the University’s medical plan addresses the application of the extended deadlines in the connection with our major medical coverage.

Overview

You generally have one opportunity each year to make changes to the University’s group health plans (i.e., active and retiree medical, dental/vision) during the University’s Open Enrollment period. However, if you experience a HIPAA special enrollment event, you may make changes outside of this enrollment period, within 31* days of the event, provided all necessary forms and required documentation are submitted to the Syracuse University Office of Human Resources within this time period.

The following events qualify as HIPAA special enrollment events: loss of eligibility for group health coverage or individual health insurance coverage; loss of Medicaid/CHIP eligibility or becoming eligible for a state premium assistance subsidy under Medicaid/CHIP; and acquisition of a new spouse or dependent by marriage, birth, adoption, or placement for adoption.

*You may make changes to your benefits coverage within 60 days if the event is due to eligibility for or loss of Medicaid or CHIP coverage.

COVID-19 Relief

Under government agency rules designed to provide relief during the COVID-19 National Emergency, the 31 (or 60) day deadline for requesting mid-year enrollment due to a HIPAA special enrollment event is extended to the date that is 31 (or 60) days following the end of the Outbreak Period.

Examples

• Employee Smith experiences a special enrollment event on Dec. 1, 2021 that requires an election within 31 days of the event. The Outbreak Period based on this event starts on Dec. 1 (the “Applicable Event Date”) and ends on Nov. 30, 2022, one year later.  Smith has 31 days from the end of the Outbreak Period (Nov. 30, 2022) to make a permitted mid-year election based on the special enrollment event.
• Employee Smith experiences a special enrollment event on July 1, 2022 that requires an election within 31 days of the event. The Outbreak Period based on this event starts on July 1, 2022 (the “Applicable Event Date”) and ends on the earlier of (a) June 30, 2023, one year after the Applicable Event Date; or (b) 60 days following the announced end of the COVID-19 National Emergency.  Smith has 31 days following the end of the Outbreak Period to file a mid-year enrollment election.

If you are a COBRA participant, please contact Lifetime Benefit Solutions at 800.493.0318 (TTY: 800.662.1220), for further information on how the extension of special enrollment deadlines may apply to your individual situation.

Each of the University-sponsored benefit plans maintain a claims procedure that governs the deadline for filing of claims, the initial disposition of filed claims by the applicable claims administrator, and the appeal of adverse determinations on a claim.  These deadlines are summarized in each of the plans. For example, claimants generally have at least 180 days to appeal an adverse determination on a claim under the University’s group health (i.e., active and retiree medical, dental/vision) and disability plans. Under the 403(b) retirement plans and life and accidental death and dismemberment plans, appeals generally must be filed within 60 days following receipt of the adverse benefit determination.

The claim and appeal deadlines for University-sponsored group health, disability, 403(b) retirement, and life and accidental death and dismemberment plans have been temporarily extended to a specific period beyond the end of the Outbreak Period depending on the event (e.g., the filing of a benefit claim or appeal).  If you are eligible for extended time to submit a claim or file an appeal, the applicable benefit vendor or insurance carrier will automatically apply the extension for you.

The COBRA relief is described in the COVID-19 Regulatory Update that is included with the COBRA election package that qualified beneficiaries are furnished at the time of a COBRA qualifying event.