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The American Rescue Plan Act offers premium assistance for members enrolled in COBRA from April 2021 to September 2021.
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For groups subject to state continuation plans (referred to as “Mini‑COBRA,” typically for those with 19 or fewer employees), Independence will provide premium assistance to eligible groups through a manual “credit” on the premium invoice. The process for obtaining credits is outlined below.
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Please note that Independence does not administer COBRA, and encourages employer groups to work with their preferred COBRA administrator and legal counsel to interpret the law as it relates to their employees.
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Obtaining Mini‑COBRA premium assistance credits
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To be eligible to obtain the Mini-COBRA premium assistance credit, customers must:
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- Be subject to state continuation plans (Mini‑COBRA), typically those with 19 or fewer employees
- Complete the Department of Labor (DOL) attestation form for each eligible subscriber and submit to Independence through the broker of record
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Brokers must complete the DOL attestation form for each individual, including the following information:
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- Subscriber First Name
- Subscriber Last Name
- Agreement Number or UMI Number
- Group Number
- Coverage Period “From” Date
- Coverage Period “To” Date
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If any of these sections are missing from the submission, brokers will be advised to re-submit the form with the missing information.
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Submitting customer information
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Brokers have 10 days to deliver the DOL attestation form to customers in order to obtain eligible premium credits for April, May, and June. See the Mini‑COBRA Credit Timing Grid for guidance on COBRA enrollment timelines and form submission dates.
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Brokers should email completed attestation forms to ibxcares@ibx.com with the subject line “Mini‑COBRA Credit Form.” Brokers should also keep a running list of submissions using our Mini‑COBRA Credit Tracker and email it to ibxcares@ibx.com after their final submission, by December 29, using the subject line: “Mini‑COBRA Credit Tracker.” Sending this summary of all submissions will act as a checkpoint to ensure all your eligible submissions are addressed.
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The deadline to submit forms for Mini-COBRA premium assistance is December 29 at 5 p.m. — no forms can be accepted beyond this date and time.
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Administering premium assistance credits
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Premium invoice credits will only appear on a future invoice after Independence receives all necessary information requested above, and the information is verified as accurate and complete.
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Customers can expect their premium invoice to reflect the billing credits in a future billing period after providing all required and necessary information as noted above. For example, if Independence is notified of an eligible employee in September, the billing credit will appear on the November invoice, which is generated in October. This may vary based on the timing of submission to Independence.
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Retro‑credits will be administered for employees who qualified for premium assistance from April 2021 to September 2021, but have since termed their coverage. These employees should be submitted using the same form and information listed above.
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If you have any questions, please contact brokerexperience@ibx.com.
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