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COVID-19 National Emergency Relief

 If I have missed a deadline under MIT during the COVID-19 pandemic, are any special extensions available?


Yes, MIT offers several key deadline extensions to help you and your family deal with any negative impact that the COVID-19 pandemic may have on your ability to satisfy the deadlines that would normally apply to your rights under the following:

  • COBRA Continuation Coverage (COBRA election, premium payment and notification of qualifying event deadlines) – these are addressed under the heading COBRA Continuation of Medical Care Coverage in our Main SPD
  • HIPAA Special Enrollment Periods (for example, deadline for adding a newborn or a dependent who lost coverage elsewhere) – these are addressed under the heading Election Changes Due to Special Enrollment in our Main SPD.
  • ERISA Claims for Benefits and Appeals of Denied Claims (deadline for filing initial claims and appealing adverse benefit determinations)– these are addressed under the heading Claims and Appeals in our Main SPD and our Medical SPD.
  • External Review of certain Claims pursuant to the ACA (deadline for requesting external review of a denied claim)– these are addressed under the heading Claims and Appeals in our Medical SPD.


Under these extensions, any deadline that would have normally expired on or after March 1, 2020 is extended for 1 year (subject to the below).


Example 1:  If you would have had until September 1, 2020 to elect to enroll in COBRA coverage through MIT, you now have until September 1, 2021 to elect COBRA.  


Example 2:  If you have a newborn that was born on July 1, 2020 and you would normally have had until August 1, 2020 to enroll him or her in your MIT coverage, you now have until August 1, 2021 to enroll your newborn.


In all events, and even if it is less than 1 year from your original deadline, no extension will apply beyond the date that is 60 days after the announcement of the end of the U.S. COVID-19 National Emergency or such other date as may be announced by the Department of Labor in a future notice (this may be different for different regions of the country).


We hope that these deadline extensions will ensure that you do not suffer an unintended loss or lapse of group health coverage or denial of a valid claim for benefits.


Please note that these deadline extensions reflect the latest guidance from the DOL and IRS, as issued through May 18, 2021.


You can read more on these COVID-19 related deadline extensions here:



How are my claims handled while the COVID-19 deadline extensions are in effect?


In general, your claims will not be paid unless and until you both elect and pay for COBRA coverage under MIT.  For example, if you have not elected COBRA coverage or are not current on your premium payment(s) for COBRA coverage, any claim submitted by your physician or other medical provider will be held by MIT until we receive your election for coverage and your required payment.


If we are contacted by your medical provider for verification of coverage during this period, we will explain that you are still within your election period and/or payment period and that coverage will retroactively take effect if your COBRA election and premium payment are received and processed by MIT.


Please note that if you do not elect and pay for COBRA coverage by the end of the deadline extension, you will be responsible for any ineligible claims that were paid by MIT on your behalf during the extended election and/or payment period.


If you want to avoid these delays in claims payment, you should continue to make your elections and pay your premiums on time.



What are my COBRA Subsidy rights under the American Rescue Plan Act of 2021?


The American Rescue Plan Act of 2021, signed by President Biden on March 11, 2021, includes generous provisions that may allow you and your family members the right to continue your MIT coverage at no cost to you during the period from April 1, 2021 to September 30, 2021 (“ARPA Subsidized COBRA”).


You are eligible for this ARPA Subsidized COBRA if either:

  1. 1. you are enrolled in COBRA during any month between April 1 and September 30, 2021 due to an involuntary termination of the covered employee’s employment or reduction of hours (other than for gross misconduct); or
  2. 2. prior to April 1, 2021 you became eligible for COBRA due to an involuntary termination of the covered employee’s employment or reduction of hours (other than for gross misconduct), which coverage would have been in place during one or more months between April 1 and September 30, 2021, but either you didn’t elect it or you elected it but then dropped it.

If you are in this second group, we should have already sent you a special enrollment election form, which allowed you a chance to re-start your COBRA coverage.  If you chose to restart your coverage, it should have taken effect on April 1, 2021, unless you elected a later date.  In either case, please note that ARPA Subsidized COBRA is only available for periods of coverage from April 1, 2021 through September 30, 2021.  If you are in this second group and did not receive a special enrollment election form, please notify MIT immediately.



Are there any ways that my ARPA Subsidized COBRA can terminate before September 30, 2021?


Yes.  Normally, your ARPA Subsidized COBRA will continue until September 30, 2021.  However, it can terminate earlier if:

  1. 1. you become eligible (regardless of whether you decide to enroll) for coverage under another group health plan (other than a plan consisting solely of excepted benefits, a QSEHRA, or a health FSA) or Medicare; or
  2. 2. your maximum COBRA coverage period expires (based on the date you were originally eligible for COBRA).

You have a duty to notify MIT if you cease to qualify for the ARPA Subsidized COBRA due to having other coverage available.  If you fail to notify MIT as required, you may be subject to a penalty of $250 for each failure (or, where fraudulent, it may increase to 110% of the premium assistance provided after you were no longer eligible).


Note that while mere eligibility for Medicare will serve to terminate your right to ARPA Subsidized COBRA, you may still have the right to continue COBRA continuation coverage on an unsubsidized basis under MIT.  Please see the FAQ entitled “How Does Eligibility for Medicare Impact my Eligibility for COBRA Coverage?” for more explanation.


How do the ARPA Subsidized COBRA rules interact with the COBRA deadline extensions?


You will continue to have until one (1) year (subject to exceptions noted above) after your original COBRA deadline to elect COBRA and to pay each of the corresponding premiums.  However, if you want your coverage to be free during the period from April 1 through September 30, 2021, you will need to make sure that you enroll during the 60-day period after you are notified of your ARPA Subsidized COBRA rights (either through a General Notice or a Notice of Extended COBRA Election Period, as applicable).


Are Participating Employers in MIT Responsible for Covering Their Former Employees’ Subsidized COBRA?


Each Participating Employer is responsible for submitted the full amount of the COBRA premium to MIT for ARPA Subsidized COBRA elected by its former employees (and their family members).  ARPA Subsidized COBRA is the result of The American Rescue Plan Act of 2021, which was signed by President Biden on March 11, 2021.  All employers participating in MIT who are or have previously been subject to COBRA continuation coverage requirements must offer ARPA Subsidized COBRA from April 2021 through September 2021 to their former employees (and their family members) who involuntarily terminated employment on or after October 1, 2019.  This includes employers who were subject to COBRA continuation coverage requirements at the time their former employees experienced a qualifying event (i.e., involuntary termination or a reduction in hours), but are no longer subject to COBRA due to a reduction in the number of employees.  For more detail, please see our participant FAQ titled “What are my COBRA Subsidy rights under the American Rescue Plan Act of 2021?”.  Note that ALL participating employers in MIT are subject to COBRA by virtue of their participation in our Plan.


In mid-April, we sent out the required Notice of Extended COBRA Election Period to all former employees of our Participating Employers whose qualifying events occurred during participation in MIT, offering them a special opportunity to enroll in Subsidized COBRA.  On an ongoing basis, we will also notify any employee who terminates employment through August 30, 2021 of his or her Subsidized COBRA rights.  For April 2021 through September 2021, your MIT invoices will reflect any of these former employees who elect to enroll in this coverage.   If your organization has former employees whose termination occurred within the past 36 months and prior to your organization’s participation in MIT, it is your responsibility to contact MIT to determine whether those individuals are entitled to notices and additional election periods under ARPA.


In most cases, you should be entitled to claim a refundable payroll tax credit for the full amount of Subsidized COBRA that you are required to provide.   The procedure to claim this payroll tax credit is similar to the method you may have used to claim payroll tax credits under the Families First Coronavirus Response Act (FFCRA).  Eligible employers may claim the credit by reporting the amount of the credit and the number of individuals receiving ARPA Subsidized COBRA on the designated lines of their federal employment tax returns, which is generally Form 941, Employer’s Quarterly Federal Tax Return.  In anticipation of receiving the credit, an eligible employer may (1) reduce its deposits of federal unemployment taxes, including withheld taxes, that it would otherwise be required to deposit, up to the amount of the anticipated credit, and (2) request an advance of the amount of the anticipated credit that exceeds federal employment tax deposits available for reduction by filing Form 7200, Advance Payment of Employer Credits Due to COVID-19.  If the tax credit exceeds the payroll taxes owed with respect to that particular quarter, the excess is refundable.  Please note that deposits of federal unemployment taxes may not be reduced, and advances may not be requested, for a credit for a period of coverage that has not begun.  Also note that, when seeking an advance of the credit, employers must file Form 7200 before the earlier of (1) the day the employment tax return for the quarter in which the employer is entitled to the credit is filed, or (2) the last day of the month following that quarter.



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Read more on the SCMA MIT Emergency Plan Amendment and view Frequently Asked Questions by clicking the link below:

SCMA MIT Emergency Plan Amendment and COVID-19 Update