55 ELM STREET HARTFORD, CONNECTICUT 06106-1775 Telephone: (860) 702-3480 Facsimile:(860) 702-3556
HEALTH CARE COST CONTAINMENT COMMITTEE
	STATE OF CONNECTICUT OFFICE OF THE STATE COMPTROLLER HEALTHCARE POLICY & BENEFIT SERVICES DIVISION

DIVISION MEMORANDUM 2010-02
TO THE HEADS OF ALL STATE AGENCIES

May 17, 2010

I. INTRODUCTION

Recent federal health reform legislation (the Patient Protection and Affordable Care Act, PL 111-148, as modified by the Health Care and Education Reconciliation Act, PL-152) requires group health plans that provide coverage for dependents to extend coverage to a subscriber's adult children up to the age of 26. The federal law amended the Internal Revenue Code to make the provision of health care coverage for these adult children a tax-free benefit.

This memorandum replaces Comptroller's Memorandum 2008-35a, which dealt with coverage for adult children under Connecticut state law, and explains how these recent changes will affect the State of Connecticut Health Plan for active employees and retirees. There will no change to eligibility rules for the dental plans, which terminate coverage for children at age 19.

II. OVERVIEW

Effective July 1, 2010, the state's self-insured medical and prescription drug plans will coordinate the federal eligibility rules with existing State-mandated coverage for adult children to age 26. As of that date coverage will be available for adult children up to the age of 26. Children who are permanently and totally disabled will remain eligible for continued coverage regardless of age. Adult children under the age of 26 who are eligible for group health coverage through their own employer's plan will not be entitled to coverage under the State's plan.

The following are included within the definition of "child": a son, daughter, stepson or stepdaughter, an individual who has been legally adopted, placed with the subscriber for legal adoption, or an eligible foster child placed with a subscriber by an authorized placement agency or by court order. When adult children "age off" the State's group health plan they have the right to continue coverage under COBRA.

III. FEDERAL TAX CHANGES

The changes in the tax code took effect upon passage of the federal legislation. As a result, the State stopped reporting the fair market value of coverage provided to Non-qualified Children on April 1, 2010. The changes to the Internal Revenue Code will eliminate requirements for annual verification of an adult child's student or dependency status and designation of an individual as a Dependent Child, Qualified Relative, or Non-qualified Child.

IV. IMPLEMENTATION

A) These changes will be implemented during Open Enrollment for retirees (May 3 to June 4, 2010) and for active employees (May 17 to June 11, 2010).

B) Subscribers who fail to add eligible adult children during this year's Open Enrollment for coverage effective July 1st will not be permitted to add such persons until the following year's Open Enrollment period, or until a Qualifying Event occurs.

C) With the exception of those who are permanently disabled, adult children will be removed from coverage automatically upon reaching age 26. The employing agency will provide the standard COBRA Notice, and the adult child will have 60 days to elect continuation of coverage beyond age 26.

V. OPEN ENROLLMENT PROCEDURE

A Subscriber seeking to enroll an adult child newly eligible for enrollment must notify the employing agency or the OSC Retirement Health Unit that they wish to enroll an adult child, and complete the standard CORE-CT Enrollment Statement or the enrollment change form in the retiree healthcare options planner for 2010-2011. The Subscriber must include a copy of the child's birth certificate or other proof of age and relationship as applicable (unless such documents are already on file with the employing agency).

The Subscriber must submit the completed Enrollment Statement and provide all required documentation to the agency by June 11, 2010. The agency will follow standard health insurance enrollment procedures to add the child to the Subscriber's coverage. It is the Subscriber?s responsibility to notify the employing agency within thirty (30) days of any change that may affect a child's eligibility for coverage.

VI. CONCLUSION

The Office of the State Comptroller will provide further information on this subject to state agencies as it becomes available. Agency personnel and payroll representatives with questions may contact Central Benefits by email at osc.benefitcorrections@po.state.ct.us , or by calling (860) 702-3535. Please do not refer employees to this number.

NANCY WYMAN, STATE COMPTROLLER

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