Expanded Spousal Definition for Group Benefits Program

In early October 2014, the U.S. Supreme Court refused to review a federal circuit court ruling requiring the Commonwealth of Virginia to recognize same-sex marriages. Consequently, the circuit court ruling requiring Virginia to recognize same-sex marriages stands. This impacts the medical, dental, vision and Medicare Part D plans in NRECA’s Group Benefits Program (GBP) because the program’s spousal definition includes a specific reference to a requirement that “…such marriage is recognized as a legal marriage by the Commonwealth of Virginia.”

In response to this action by the Supreme Court, NRECA is amending the GBP’s spousal definition with an effective date of October 6, 2014 (the date of the Supreme Court decision). This revision will extend the opportunity for coverage to a spouse, and any eligible dependents of the spouse or eligible employee, who became eligible for coverage under the GBP as a result of this expanded definition as of October 6, 2014 or the date of their marriage—whichever is later. This change will also necessitate a special 31-day enrollment window for participants at co-ops in states where same-sex marriages are now legally recognized. The group life program offered through MetLife does not require an amendment as the current definition is sufficiently defined to recognize legal marriage. However, impacted participants will be given the opportunity to elect coverage in the group life plan.

The special enrollment window will open on November 1 and will run through December 1, 2014. A special enrollment form will be available during the enrollment window to separately track these elections for the medical, dental, vision and life insurance plans for 2014. Eligible employees interested in making these benefit plan changes for 2015 will need to complete your co-op’s normal annual enrollment process. Future new hires and marriages can be processed through the regular new hire and marriage events on NRECA’s Employee Benefits website. Retirees eligible for the Medicare Part D Plan and interested in making a change in 2014 will need to complete a Medicare Part D enrollment form and return it to their benefits administrator to enter on the Medicare Part D website.

Impacted States and Next Steps
Benefits administrators and CEOs at co-ops located in one of the following states will receive an email on Thursday, October 30 with additional information as well as template letters that can be used to notify eligible employees and retirees of this change. As of October 20, 2014, 32 states and the District of Columbia legally recognize same-sex marriages: Alaska, Arizona, California, Colorado, Connecticut, Delaware, Hawaii, Idaho, Illinois, Indiana, Iowa, Maine, Maryland, Massachusetts, Minnesota, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin and Wyoming.

In the future, as states change their definition of marriage, NRECA will open special enrollment events for co-ops in those states.

NRECA Retirement Plans
In 2013, NRECA clarified that NRECA’s 401(k) Pension and Retirement Security Plans’ spousal definition is based upon the employee’s marriage state of celebration. As a result, there is no further change required in these programs as a result of the recent action by the Supreme Court.

Questions
If you have any questions about this change or its impact to your co-op, please contact your local field representative or NRECA’s Member Contact Center at 866.673.2299 or via email at contactcenter@nreca.coop.