Citi Benefits Handbook
Changing Your Coverage
Qualified Changes in Status
The rules regarding qualified changes in status apply to coverage elections you make for medical, dental, vision, Health Care Spending Account (HCSA), Limited Purpose Health Care Spending Account (LPSA), Dependent Day Care Spending Account (DCSA), Long-Term Disability (LTD), Group Universal Life (GUL) insurance and Supplemental Medical Plans.
Please note that the qualified change in status rules do not apply to enrollment in the MetLife Legal Plans. If you enroll during annual enrollment, you will not be able to make a change in your coverage until the next annual enrollment.
In general, the benefit plans and coverage levels you choose during Annual Enrollment remain in effect for the remainder of the following calendar year. However, you may be able to change your elections between Annual Enrollment periods if you have a qualified change in status or other applicable event, as explained below.
You must report to the Citi Benefits Center any change of status that affects your benefits within 31 days of the qualified event by following the process described under "How to Report a Qualified Change in Status Event."
Exceptions to the 31-day rule are the loss of Medicaid or Children's Health Insurance Program (CHIP) coverage and the start of eligibility for state premium assistance. For these two events, you have 60 days to report a change of status and change your benefits.
Do not report qualified changes in status to your medical plan carrier. Your medical plan carrier must receive status change information from Citi, not from you.
Depending on the event, you may be permitted to:
- Enroll in or drop your medical, dental, vision, HCSA, LPSA or DCSA coverage;
- Increase or decrease the amount of your HCSA, LPSA or DCSA coverage;
- Enroll in LTD without having to provide evidence of good health; and
- Enroll in or increase GUL insurance without having to provide evidence of good health. (You may increase your coverage if the first, second, third or sixth events below apply. When you experience one of those events, if you have not elected the GUL maximum benefit, you may elect to increase your GUL coverage by one times your benefits eligible pay, not to exceed $500,000, without providing evidence of insurability. Initial election of spouse/partner or child coverage under this program, respectively, is available if you marry, establish an eligible partnership or in the event of the birth or adoption of a child.)
Examples of qualified changes in status are:
1. Your marriage, legal separation or divorce;
2. Meeting the eligibility to qualify as a partner;
3. The birth or adoption of a child;
4. The loss of coverage eligibility for a dependent child who, for example, becomes ineligible due to age;
5. The loss of coverage under your spouse's/partner's or other employer's plan;
6. The death of a spouse/partner or dependent child;
7. The issuance of a Qualified Medical Child Support Order (QMCSO);
8. Relocation outside your medical and/or Cigna Dental HMO's network area;
9. The start of a military leave of absence;
10. The loss of group Basic Life insurance;
- If your benefits eligible pay for benefits purposes increases such that you become ineligible for company-paid Basic Life and Basic AD&D, this loss of coverage constitutes a qualified change in status for enrollment in GUL insurance. If you have not previously elected the maximum coverage under GUL, during Annual Enrollment you can elect GUL equal to one times your benefits eligible pay, not to exceed $500,000, without providing evidence of good health.
11. The loss of CHIP coverage; and
12. The start of eligibility for state premium assistance.
If you are eligible for health coverage from Citi but are unable to afford the premiums, some states have premium assistance programs that can help pay for coverage. These states use funds from their Medicaid or CHIP programs to help people who are eligible for employer-sponsored health coverage but need assistance in paying their health premiums. If you or your dependents are already enrolled in Medicaid or CHIP, you can contact your state Medicaid or CHIP office to find out if premium assistance is available.
If you or your dependents are not enrolled in Medicaid or CHIP, and you think you or any of your dependents might be eligible for either of these programs, contact your state Medicaid or CHIP office or call 1 (877) KlDS NOW or visit www.insurekidsnow.gov to find out how to apply. If you qualify, you can ask the state if it has a program that might help you pay the premiums for an employer-sponsored plan.
Once it is determined that you or your dependents are eligible for premium assistance under Medicaid or CHIP, Citi will permit you and your dependents to enroll in the Plans, as long as you and your dependents are eligible but not already enrolled in the Plans. This is called a "special enrollment" opportunity, and you must call the Citi Benefits Center and ask to enroll within 60 days of being determined eligible for premium assistance.
The following is a list of qualified changes in status that will generally allow you to change your elections within 31 days of the occurrence of the qualified change in status (as long as you meet the consistency requirements, as described below). Note that a HIPAA special enrollment event includes loss of eligibility for another group health plan or health insurance that you or your dependents are enrolled in and gaining an eligible dependent through a birth, marriage, or adoption.
- Legal marital status: Any event that changes your legal marital status, including marriage, divorce, death of a spouse, legal separation or annulment;
- Domestic/civil union partnership status: You enter into or terminate a domestic/civil union partnership;
- Number of dependents: Any event that changes your number of tax dependents, including birth, death, adoption and placement for adoption;
- Employment status: Any event that changes your, your spouse's/partner's or another dependent's employment status that results in gaining or losing eligibility for coverage. Examples include:
- Beginning or terminating employment;
- A strike or lockout;
- Starting or returning from an unpaid leave of absence;
- Changing from temporary to permanent employment or vice versa;
- Changing from part-time to full-time employment or vice versa; and
- A change in work location;
- Dependent status: Any event that causes your tax dependents to become eligible or ineligible for coverage because of age; and
- Residence: A change in the place of residence for you, your spouse/partner, or another dependent if outside your medical or Cigna Dental HMO's network area.
Coverage changes will be administered in accordance with applicable Treasury Regulations (Treasury Regulation section 1.125-4).
The following are rules that are applicable to a qualified change in status. Any change in benefits request, including the ones discussed below, in connection with a qualified change in status must be made within 31 days of the occurrence of the qualified change in status, except as otherwise indicated.
Consistency Requirements
The changes you make to your medical, dental, vision and spending account coverage must be "due to and consistent with" your qualified change in status. To satisfy the federally required "consistency rule," your qualified change in status and corresponding change in coverage must meet both of the following requirements.
- Effect on eligibility: The qualified change in status must affect eligibility for coverage under the Plan or under a plan sponsored by the employer of your spouse/partner or other dependent. For this purpose, eligibility for coverage is affected if you become eligible (or ineligible) for coverage or if the qualified change in status results in an increase or decrease in the number of your dependents who may benefit from coverage under the Plan.
- Corresponding election change: The election change must correspond with the qualified change in status. For example, if your dependent loses eligibility for coverage under the terms of the health plan, you may drop medical coverage only for that dependent. Additionally, you may increase or start contributions to an HCSA or an LPSA if you add a dependent. The Plan Administrator will determine whether a requested change is due to a qualified change in status and is consistent with the qualified change in status.
Coverage and Cost Events
In some instances, you can make changes to your benefits coverage for other qualifying events, such as midyear events affecting your cost or coverage, as described below. To change your coverage, the qualifying event must be reported within 31 days; however, in no event will any cost or coverage event allow you to make a change to your HCSA or your LPSA election.
Coverage Events
If Citi adds or eliminates a plan option in the middle of the plan year, or if Citi-sponsored coverage is significantly limited or ends, you and your eligible dependents can elect different coverage in accordance with the Internal Revenue Service (IRS) regulations.
For example, if there is an overall reduction under a plan option that reduces coverage to participants in general, participants enrolled in that plan option may elect coverage under another option providing similar coverage (if the other plan option permits). Additionally, if Citi adds an HMO or other plan option mid-year, participants can drop their current coverage and enroll in the new plan option (if the new plan option permits). You and/or your eligible dependents may also enroll in the new plan option even if not previously enrolled for coverage at all (if the new plan option permits).
Also, if an election change is permitted during a different Annual Enrollment period applicable to a plan of another employer, you may make a corresponding midyear election change.
If another employer's plan allows your spouse or other dependent to make a midyear change to his or her elections in accordance with IRS regulations, you may make a corresponding midyear election change to your coverage.
Cost Events
You must contact the Citi Benefits Center within 31 days to make a change as a result of a cost event. Otherwise, your next opportunity to make changes will be the next Annual Enrollment period or when you have a qualified change in status, whichever occurs first.
If your cost for medical, dental or vision coverage increases or decreases significantly during the year, you may make a corresponding election change. For example, you may elect another plan option with similar coverage, or drop coverage if no alternative coverage is available. Additionally, if there is a significant decrease in the cost of a plan option during the year, you may enroll in that plan option, even if you declined to enroll in that plan option earlier.
Any change in the cost of your plan option that is not significant will result in an automatic increase or decrease, as applicable, in your share of the total cost.
Other Rules
Medicare or Medicaid entitlement: You may change an election for medical coverage midyear if you, your spouse/partner or your eligible dependent becomes entitled to, or loses entitlement to, coverage under Part A or Part B of Medicare or under Medicaid. However, you are limited to reducing your medical coverage only for the person who becomes entitled to Medicare or Medicaid, and you are limited to adding medical coverage only for the person who loses eligibility for Medicare or Medicaid.
Family and Medical Leave Act (FMLA): You may drop medical (including the HCSA and the LPSA), dental and vision coverage midyear when you begin an unpaid leave, subject to the provisions of the Family and Medical Leave Act (FMLA). If you drop coverage or if you fail to make payments for benefits coverage during your FMLA leave, when you return from the FMLA leave, you have the right to be reinstated to the same elections you made prior to taking your FMLA leave.
Special note regarding partner coverage: The events qualifying you to make a midyear election change described in this section also apply to events related to a partner. However, IRS rules generally do not permit you to make a midyear change on a before-tax basis for such events unless they involve a tax dependent. Thus, if you make a midyear change due to an event involving your partner, generally that change must be made on an after-tax basis, unless your partner can be claimed as your dependent for federal income tax purposes. See IRS Publication 17, Your Federal Income Tax, for a discussion of the definition of a tax dependent. The publication is available at www.irs.gov/formspubs/index.html.
Special enrollment rights: If you or your dependents become eligible for premium assistance or lose eligibility for Medicaid or a state's CHIP, you have special enrollment rights under the Plans. You must contact the Citi Benefits Center to request to enroll in coverage under a medical plan option within 60 days of the noted occurrence.
Medicaid and CHIP offer free or low-cost health coverage to children and families.
If you are eligible for health coverage from Citi but are unable to afford the premiums, some states have premium assistance programs that can help pay for coverage. These states use funds from their Medicaid or CHIP programs to help people who are eligible for employer-sponsored health coverage but need assistance in paying their health premiums. If you or your dependents are already enrolled in Medicaid or CHIP, you can contact your state Medicaid or CHIP office to find out if premium assistance is available.
If you or your dependents are not enrolled in Medicaid or CHIP, and you think you or any of your dependents might be eligible for either of these programs, contact your state Medicaid or CHIP office, call 1 (877) KIDS NOW or visit www.insurekidsnow.gov to find out how to apply. If you qualify, you can ask the state if it has a program that might help you pay the premiums for an employer-sponsored plan.
Once it is determined that you or your dependents are eligible for premium assistance under Medicaid or CHIP, Citi will permit you and your dependents to enroll in the Plans, as long as you and your dependents are eligible but not already enrolled in the Plans.