FREQUENTLY ASKED QUESTIONS -HCTC Updated 03/24/20

The Board of the DSRA-BT has already received many questions regarding the HCTC. If you don't see an answer to your question, please send an e-mail to Lori Ostrander, Secretary. Her e-mail can be accessed through the DSRA-BT website under "Contact Us".

2020 Open Enrollment

FAQ #1: Will I have to submit a new 13441-A enrollment form for 2020?

ANSWER: Yes, the IRS is requiring a new 13441-A enrollment form for all HCTC AMP participants for 2020 due to the temporary termination of the HCTC program at the end of 2019.  The 13441-A form should be submitted to Benistar Retiree Services 6-8 weeks before enrollment into the HCTC program.

FAQ #2:  Do I need to submit a new 13441-A form if I am changing my level of coverage in 2020? 

Answer:  Yes, you must complete and submit an updated 13441-A form with the new plan level premium amount if you are changing your plan level.  The update form should be sent to the Benistar Retiree Service Center 6-8 weeks prior to the change in coverage level.

 

FAQ #3: If I am enrolled in the DSRA-BT BCBSM medical plans but not the AMP (Advance Monthly Payment Program) for December 2019, and want to enroll in the AMP for the first time effective January 2020, what do I need to do?

ANSWER:

  1. Review the 13441-A Sample forms available on this website. A sample form is available at the following link to help guide you (use New AMP Enrollees file): https://www.dsrabenefittrust.net/dsrabene/index.php/document-center/Health-Coverage-Tax-Credit-(HCTC)/Sample-Documents/
  2. Print a blank 13441-A form available at https://www.irs.gov/pub/irs-pdf/f13441a.pdf
  3. Using the Sample form, complete the 13441-A enrollment form
  4. Locate and make a copy of your Proof of Eligibility (i.e.- PBGC Payment Notice Letter, PBGC payment check stub, Bank Statement with your name and PBGC payment made into your account)
  5. Print and complete the DSRA Enrollment form available at DSRABenefitTrust.net
  6. Mail, fax or email the signed and completed 13441-A form, the signed and completed DSRA Enrollment form along with your Proof of Eligibility to the Benistar Retiree Service Center, 10 Tower Lane, Suite 100, Avon CT 06001, (Fax) 1-860-408-7025, (Email) This email address is being protected from spambots. You need JavaScript enabled to view it.

The IRS/HCTC may take up to 8 weeks to process your enrollment forms.  As soon as you receive the “Enrolled Letter” from the IRS, call the Benistar Retiree Service Center 1-888-588-6682 and provide them with your Participant Identification Number (PIN).  You must continue to pay 100% of the BCBSM premium to Benistar until you have received the “Enrolled Letter”.  The 27.5% payment for the BCBSM premiums are due by the 10th of each month to the IRS.  Print out IRS form #13973 and mail with your payment.  If you miss the HCTC AMP premium payment deadline or if you have already paid the 100% BCBSM premium payment to Benistar for the month, you will begin the HCTC AMP 27.5% payment process the following month.

 

FAQ #4: If I am not an enrollee in the DSRA-BT medical plans for December 2019, and I want to enroll in a HCTC AMP DSRA-BT medical/dental/vision bundled plan from BCBSM for 2020, what do I need to do?

ANSWER:

  1. Review the 13441-A Sample forms available on this website. A sample form is available at the following link to help guide you (use New AMP Enrollees file): https://www.dsrabenefittrust.net/dsrabene/index.php/document-center/Health-Coverage-Tax-Credit-(HCTC)/Sample-Documents/
  2. Print a blank 13441-A form available at https://www.irs.gov/pub/irs-pdf/f13441a.pdf
  3. Using the Sample form, complete the 13441-A enrollment form
  4. Locate and make a copy of your Proof of Eligibility (i.e.- PBGC Payment Notice Letter, PBGC payment check stub, Bank Statement with your name and PBGC payment made into your account)
  5. Print and complete the DSRA Enrollment form available at DSRABenefitTrust.net
  6. Mail, fax or email the signed and completed 13441-A form, the signed and completed DSRA Enrollment form along with your Proof of Eligibility to the Benistar Retiree Service Center, 10 Tower Lane, Suite 100, Avon CT 06001, (Fax) 1-860-408-7025, (Email) This email address is being protected from spambots. You need JavaScript enabled to view it.

The IRS/HCTC may take up to 8 weeks to process your enrollment forms.  As soon as you receive the “Enrolled Letter” from the IRS, call the Benistar Retiree Service Center 1-888-588-6682 and provide them with your Participant Identification Number (PIN).    You must continue to pay 100% of the BCBSM premium to Benistar until you have received the “Enrolled Letter”.  The 27.5% payment for the BCBSM premiums are due by the 10th of each month to the IRS.  Print out IRS form #13973 and mail with your premium payment. 

 

Subsidies

FAQ#1: Why is the DSRA-BT subsidy limited to those salaried retirees who retired on or before April 1, 2009?

ANSWER: The Trust Agreement approved during the Delphi bankruptcy clearly stipulates that the limited funds paid to the Trust by Delphi were specifically for the benefit of those retired and receiving their pension as of April 1, 2009. Please see the Trust agreement posted at the DSRA BT website

 

FAQ #2: Are the DSRA BT subsidy guidelines changing for 2020?

ANSWER: Yes, the guidelines for who is eligible for a DSRA BT subsidy were expanded to include HCTC eligible participants for January and February of 2020 to accommodate the delay in reauthorization of the HCTC program.  The DSRA BT guidelines from March 2020 through the end of the year then reverted back to the 2019 guidelines.  See the 2020 Subsidy section of the Guide for more details.

 

FAQ #3: I am the retiree from Delphi and I am over 65 but my spouse is under 65.  Do they qualify for the HCTC?  If they don’t, is a subsidy offered to help offset their premium cost?

ANSWER: Your spouse is eligible for the HCTC until you reach age 67 if they are under 65.  At age 67, when HCTC eligibility ends, the pre-65 spouse will be eligible for a DSRA-BT QFM subsidy for 24 months (if you are a salaried retiree and retired on or before April 1, 2009) until the retiree reaches the age of 69 or the spouse reaches age 65, whichever comes first. The DSRA-BT does not offer a subsidy for the QFM once the retiree reaches age 69.  To receive this DSRA-BT subsidy, a new enrollment form must be submitted to Benistar requesting the subsidy.  This is required, even from current enrollees.

 

FAQ #4: I retired before April 2, 2009 but have delayed drawing my PBGC pension.  Do I qualify for a subsidy since I am not eligible for the HCTC?

ANSWER: No, you must have started drawing your PBGC pension prior to April 2, 2009 to be eligible for a subsidy.

General Questions

FAQ#1: When does the HCTC expire?

ANSWER: The reauthorized HCTC is set to expire 12-31-2020.

 

FAQ#2: Is Dental and Vision insurance eligible for the HCTC?

ANSWER: Yes, they are eligible if you also have bundled medical coverage from BCBSM.  In fact, if you are in the HCTC AMP you are required to have dental & vision. If you have stand-alone dental and vision, the HCTC does not cover their premium cost.

 

FAQ#3: If I'm still working, can I sign up for health care and the HCTC when I retire and not wait for the next open enrollment window?

ANSWER: YES. Retirement (involuntary loss of other insurance coverage) is a "Qualifying Event" and as a result makes you eligible to change your medical coverage without waiting for the annual open enrollment window.

 

FAQ #4: Do I have to enroll in the HCTC AMP to get the HCTC?

ANSWER: NO, you can purchase a Non-HCTC plan from the Trust and recoup the HCTC on your tax return through IRS form 8885. Or you can buy an HCTC eligible plan from another carrier and recoup the HCTC on your tax return. If you plan to use the tax return method to recoup the HCTC, you do not have to buy a bundled plan. In this situation, you have the flexibility to decide if you want to bundle dental and or vision coverage.

 

HCTC Eligibility

FAQ#1: Who qualifies for the HCTC?

ANSWER: You qualify for the HCTC if you receive your pension from the PBGC, you are 55-64 years of age and you are not receiving coverage through Medicare. There are other ways to meet the eligibility requirements for the HCTC. They can be found at the IRS website. We suggest that you bookmark the following link from the IRS and review periodically for any new updates: https://www.irs.gov/Credits-&-Deductions/Individuals/HCTC.

 

FAQ#2: Are all four medical plans offered by the DSRA-BT, through BCBSM, eligible for the HCTC?

ANSWER:
YES, all pre-65 medical plans offered by the VEBA in Non-Medicare situations are HCTC eligible.

 

FAQ #3: If I buy my healthcare through the government health insurance marketplace (Obamacare), do I qualify for the HCTC?

ANSWER: No, the plans in Obamacare are not eligible.

 

FAQ#4: Will the HCTC apply to those over 65?

ANSWER: The HCTC does not apply to individuals that are 65 or older, or on Medicare.

 

FAQ#5: What happens to our eligibility for the HCTC if we win our pension battle?

ANSWER: We clearly want to maintain HCTC eligibility when we win the pension battle.  All of our current scenarios take this into account according to our legal team.  Maintaining the HCTC is a priority.

 

FAQ#6: If I'm not eligible for the QFM subsidy, can my spouse change their medical plan when they lose the HCTC?

ANSWER: Yes, loss of the HCTC is considered a “Qualifying Life Event” (QLE).  As such, you are eligible to downgrade your plan (i.e. from Gold to Copper) if you wish.  We also asked the IRS if the government would consider it a QLE so a person could enroll in an ACA plan in the Marketplace mid-year.  Their response was that it would make sense that the loss of the majority of funding would be a qualifying event.  That said, the IRS would not give us an answer, and instead indicated that the member would need to contact the Marketplace in the state where they are purchasing a policy and get an individual determination.

 

FAQ#7: I am a Surviving Spouse of a retiree whose pension is administered by the PBGC. Am I eligible for the HCTC?

ANSWER: If your retired spouse had the surviving spouse (SS) option as a part of his/her pension, once you initiate the SS option and become the pensioner of record with the PBGC and start receiving benefits, you are now eligible for the HCTC for as long as the HCTC is in effect. You must purchase qualified medical insurance and be age 55-64. In this situation, the QFM guidelines and limitations do not apply.



FAQ #8:  What happens to coverage in the event of a change in marital status (spouse)?

Answer:
An acquired spouse may be added to your coverage upon marriage. A former spouse is eligible if he or she provides a statement from the PBGC confirming that he/she has become a pension recipient in his or her own right due to the divorce (under a QDRO). A former spouse is not eligible for coverage in the medical, dental or vision plans unless eligible for PBGC pension, except for a former spouse who is a QFM within 24 months of divorce. A former spouse is NOT eligible for voluntary term life insurance.

 

FAQ #9:  I am divorced from a Delphi retiree and as part of the divorce decree I am receiving a portion of their PBGC pension.  Do I qualify for the HCTC?

ANSWER: Yes, if you meet the eligibility requirements of the HCTC program; being between the ages of 55-64, drawing a pension check from the PBGC and enrolled in a qualified insurance plan, you qualify for the HCTC. You are considered a PBGC pensioner, just like your ex-spouse, so long as the HCTC is in effect, you can take advantage of this benefit. The qualified family member limitations do not apply any longer.  The PBGC uploads eligibility records monthly but depending on when you are identified as a pensioner, your Social Security Number (SSN) may come up as ineligible. To help avoid any issues, we strongly encourage attaching a letter of eligibility (from PBGC) or a 1099-R (showing pension distribution) so if your SSN does show up as ineligible, it can be overridden.

 

FAQ #10: Is COBRA coverage thru GM or Delphi eligible coverage for the HCTC subsidy? What about from other auto employers that purchased Delphi operations?

ANSWER: YES, if you pay more than 50% of the cost of your COBRA insurance, and meet the eligibility requirements of the HCTC program, you qualify for the HCTC.  However, these plans are not eligible for the HCTC AMP program.  You must file form 8885 on your tax return the following year to recoup the 72.5% of premiums paid.

 

FAQ#11:  If I have COBRA coverage from any previous employer, can I sign up for a DSRA-BT plan when this expires, even if it’s mid-year?

ANSWER: Yes, expiration of COBRA coverage would be considered a “Qualifying Life Event”.

 

FAQ #12: Can my spouse go on one of your plans and utilize the HCTC while I stay on COBRA?

ANSWER: YES, spouses have the ability to enroll in the HCTC program and qualified insurance plan as an individual without the retiree enrolling. 

 
FAQ #13:  Must you be drawing your pension from the PBGC to receive the HCTC?

ANSWER:
YES, you must be drawing your PBGC pension to qualify.

 

FAQ #14:  If I retire mid-year, is the HCTC retroactive back to the first of the year?

ANSWER: No, the HCTC will be available effective the 1st day of the month you start drawing your pension from the PBGC.

 

FAQ #15: We have Delphi Hughes retirees in California that chose to take their Delphi/GM pension over a fixed period of 5 or 10 years. They were also promised health insurance until age 65. Will they continue to be eligible for the HCTC until age 65 once their pension has been paid to them in full by the PBGC?

ANSWER: Current interpretation is that once you no longer receive a PBGC pension, you are no longer eligible for the HCTC.  However, these people will be eligible for a DSRA-BT subsidy if they satisfy the following conditions:

  1. Delphi Salaried retiree
  2. Retirement date previous to 4-2-2009
  3. Be the Age of 55 to 64
  4. Provide proof of lump sum distribution or agreement between both parties to a defined time period of pension payments.

 

FAQ #16:  I am a Delphi salaried retiree who is Medicare Disabled and under 65.  Does my under 65 spouse qualify for the HCTC or a DSRA-BT subsidy?

ANSWER:  Your spouse qualifies for the HCTC until you have been on Medicare for 24 months.  At that point, they qualify for a DSRA-BT Special Circumstance subsidy if you retired on or before April 1, 2009 and they are still under 65.

Sample 13441-A Forms for various situations can be found at the following link: https://www.dsrabenefittrust.net/dsrabene/index.php/document-center/Health-Coverage-Tax-Credit-(HCTC)/Sample-Documents/

Refer to the Questions and Answers (https://www.irs.gov/individuals/hctc-health-plans-q-and-a) on the IRS website for further guidance on the types of health insurance coverage that qualify for the HCTC in 2020.

2020 OPEN ENROLLMENT Call BENISTAR with ALL QUESTIONS 888-588-6682
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