Although the deadline for making COBRA premium payments is generally 30 days from the beginning of each month (or 45 days for the initial payment), an extension may apply in certain circumstances as described in the following examples:
- Example 1: On March 1, 2020, Lanae was receiving COBRA continuation coverage with HMAA. More than 45 days had passed since Lanae elected COBRA, and monthly premium payments are due on the first day of the month. Although Lanae made a timely payment for February, she is unable to make subsequent monthly payments due to the COVID-19 pandemic. What is the deadline for Lanae to pay outstanding monthly premiums to continue receiving COBRA continuation coverage? For purposes of determining whether COBRA premium payments are timely, the Outbreak Period is disregarded. Lanae will be covered by HMAA for all outstanding months as long as she pays all premium payments for those outstanding months within 30 days after the Outbreak Period (March 1, 2021), in this case by the deadline (March 30, 2021).
- Example 2: What if Lanae (referred to in Example 1) is unable to make the premium payments for all outstanding months within 30 days after the Outbreak Period? Lanae would only be entitled to COBRA continuation coverage for the months in which timely premium payments were made and would not be entitled to coverage for any months in which she was not able to make those payments in full. In addition, Lanae could not choose how she would like her payments applied; payments would automatically be applied to the outstanding months sequentially. For example, if Lanae is able to pay for 3 outstanding months, continuation of coverage would extend through March, April and May. She would lose coverage on June 1, 2020 and HMAA would not cover benefits or services incurred after May 31, 2020.