The most recent “extension” of the original ARRA health insurance subsidy is set to expire on May 31, 2010. As of this writing (as seems to be the case with the current political climate), no “fix” has been completed yet BEFORE the actual expiration date of the government program. The initial passage of ARRA and the subsequent “extensions” of the subsidies have all been enacted to retroactive implementation dates.
There is a current law pending in the house called the “American Jobs and Closing Tax Loopholes Act” which (in its current form) would extend the subsidy until yearend. Based on what we are seeing, we are not expecting it to be completed before the summer recess (scheduled from May 29th to June 6th). And of course once the House passes the bill, it will need to move to the Senate for approval and then ultimately to the President for his signature. It is worth noting that this administration has proven on numerous occasions that once a bill starts to move, they are able to move it through the process quite quickly—even if it will need to be on a retroactive basis.
Meanwhile, at the State level, on Saturday, May 15th, Governor Quinn quietly amended the Illinois Continuation laws that intended to extend Illinois Continuation eligibility to ARRA subsidy eligible individuals to 15 months in order to coincide with the Federal ARRA subsidy program.
NON-subsidy eligible Illinois Continuees appear to still have 12 months of Illinois Continuation. We have reached out to all of our carriers for their interpretation/administration of the above referenced amendments. Although all the carriers acknowledged that they were aware of the legislation, BCBSIL is the only insurer that has acknowledged that they are presently offering/ administering Illinois Continuation for up to 15 months for ARRA subsidy individuals (the materials reflected on BCBSIL’s website may not reflect this most recent change). The other carrier responses ranged from they were still reviewing the legislation and waiting for DOI responses/ clarifications or that they were waiting for corporate policy to be officially promulgated.
Rather than waiting for the carriers to take a position, we wanted to make sure you were aware of the legislation that is “out there” and what the DOI most likely will be telling your clients if they were to call or email the DOI about their Illinois Continuation/ARAA subsidy eligibility. Resource Brokerage was in contact with the DOI directly regarding this state law as soon as it passed to see what guidance they could provide, and the above synopsis summarizes our lengthy communications with them. But as we all know, from time to time, carriers will interpret/administer the same legislation differently. We will keep you posted as soon as more information becomes available on both the Federal and State levels!
