CHIPRA Eligibility

[GMK]

Employee's child lost state CHIP health coverage on March 1.

Employee applied for coverage for the child and herself under company group health plan in April (more than 30 days but less than 60 days after loss of CHIP coverage).

Does the special 60-day enrollment period under CHIPRA apply if the loss of coverage occurs before April 1, 2009?

Haven't found any official guidance yet. All comments are welcome. Thanks.

[GMK]

According to Section 3. General Effective Date, etc., of CHIPRA (Public Law 111-3):

"...this Act ... shall take effect on April 1, 2009, and shall apply to child health assistance and medical assistance provided on or after that date." (with exceptions for the timing of state legislation).

Anyway, it looks like there is no requirement to provide the special 60 day enrollment period if the loss of coverage occurred before April 1, 2009.

Or is there something I missed here? Thanks for your comments.