In this episode, Jill Brooking joins Chase Cannon to discuss the impact the government shutdown may have on employer group health plans, particularly for governmental contractors, whose employees may be out of work due to the shutdown. Jill breaks down the benefits issues employers should look at for employees that are out of work or on furlough as a result of the shutdown, including plan eligibility terms and carrier (or stop-loss) contracts, and the risks in covering employees outside the plan’s eligibility terms. Jill describes how the ACA’s employer mandate may impact an employer’s offer of coverage, depending on whether the employer is using measurement/stability periods for employees. Jill also discusses premium payment options for employers and employees during an unpaid leave of absence, and at what point COBRA comes into play. Lastly, Jill and Chase discuss what should happen when – if ever – the government shutdown ends, including collecting premiums in arrears and the rehire rules under both Section 125 and the ACA’s employer mandate.
