health plan for disabled individuals?

[chris]

Employer is a non-profit that employees blind indivudals. Employer wants to put in a medical expense reimbursement plan. Any way to do this given the disability issue? Plan document for medical expense reimbursement plan generally provides for ineligibility once participant becomes disabled. Also, disability seems to be a qualifying event under COBRA upon which the disabled individual is to pay 150% of the costs of the benefits under the plan. Any ways around those two issues. Bottom line is that employer wants to provide as much as it can to the employees without negatively affecting their SSI Disability, Medicare, Medicaid, etc... coverages......? Thanks for any help.

[GBurns]

While I have seen many health/medical plans that have that ineligibility wording, I have never seen such wording in any MERP of any sort. Why would such a ineligibility clause be in a MERP?

I am also not familiar with this 150% requirement. 150% of the cost of what benefits?

I have also never seen where reimbursements from a MERP, whether FSA or other, were included in any calculation for eligibility or benefits related to SSI etc. Why would such reimbursements be a concern? Have you seen something somewhere that infers that such reimbursements would be regarded as income or as an asset?

[Mary C]

The COBRA provision that requires 150% of the cost for disabled individuals is only if the disabled individual is on COBRA and meets the requirements to extend the coverage from the normal 18 month COBRA period to 29 months. The disabled then pays 150% of the cost or premium for months 19 to 29. This shouldn't have any bearning or consideration on a healthcare plan or medical reimbursement plan for ACTIVE employees.

[chris]

My issue concerns the fact that all of these employees are disabled according to the employer. The employer only employees blind individuals. On the basis of being blind, these individuals are already receiving Social Secuirty disability as well as Medicaid in some cases. The go-by medical expense reimbursement plan document was a sample document in the Appendix of one of the Tax Management Portfolios published by the Bureau of National Affairs (BNA). Thus, the employer reviewed the sample plan document and pointed out that the language re disability causing a participant to cease eligibility, the COBRA language, etc...... would apply at day one since all of the employees are blind, i.e., disabled.