Department of Civil Service

PA95-05

TO: Health Benefits Administrators
FROM: Employee Benefits Division
SUBJECT: Domestic Partner Coverage Transactions
DATE: April 3, 1995

Our memorandum 95-02, dated January 27, 1995, provided you with information concerning the optional domestic partner coverage you may extend to your employees who are enrolled in the New York State Health Insurance Program.

This memorandum will explain how to complete the PS-503.1 transaction form needed to enroll the domestic partner. Also, a schedule is attached which will assist you in estimating the imputed (taxable) income to the enrollee as a result of enrolling a domestic partner.

During your initial enrollment period, when coverage for the domestic partner will be effective on the first day of the month following the date of request (enrollee's signature date), you should send your completed PS-503.1 along with the affidavits to the Employee Benefits Division, Attention: PA Unit. After the initial enrollment period, when the regular effective date rules will apply, send the original PS-503.1 to Blue Cross, and send a copy of the PS-503.1 to Employee Benefits Division along with the affidavits.

The memorandum 95-02 stated that employers that elect to extend this benefit must provide it for active employees, vestees and retirees. This is incorrect. An employer may have different domestic partner coverage availability based on their classes or categories of active as well as non-active employees. The decision for one class or category has no bearing on the other classes or categories.

Adding a Domestic Partner to an Individual Coverage

A CCO transaction changing the coverage to family should be completed in the usual manner except that you should note the following:

Item 8 Spouse's Social Security Number

Complete with the domestic partner's social security number.

Item 14 Date of Event

The enrollee and the domestic partner must have been involved in the partnership for a period of at least six months before the domestic partner can be considered eligible for coverage under the New York State Health Insurance Program. Therefore, the date of event is calculated as six months from the most recent date on the documents of proof that are submitted with the application.

Item 17 List of Eligible Dependents

When adding a domestic partner the relationship should be completed as follows: for a female use "Female DP" and for a male use "Male DP." Children of the domestic partner may also be eligible for coverage. They must meet the qualifications of "other children who reside permanently in the employee's household" (refer to section 101 in the PA Manual, particularly item number 2). Any children being added to the family coverage can be listed in the usual manner (for example: son, daughter, son of DP, or daughter of DP).

Adding a Domestic Partner to an Existing Family Coverage

An ADD transaction should be completed to add the domestic partner to the family coverage. Note the following:

Item 8 Spouse's Social Security Number

Complete with the domestic partner's social security number.

Item 17 List of Eligible Dependents

When adding a domestic partner the relationship should be completed as follows: for a female use "Female DP" and for a male use "Male DP." Children of the domestic partner may also be eligible for coverage. They must meet the qualifications of "other children who reside permanently in the employee's household" (refer to section 101 in the PA Manual, particularly item number 2). Any children being added to the family coverage can be listed in the usual manner (for example: son, daughter, son of DP, or daughter of DP).

Item 20 Effective Date

The enrollee and the domestic partner must have been involved in the partnership for a period of at least six months before the domestic partner can be considered eligible for coverage under the New York State Health Insurance Program. Therefore, the effective date of the ADD is either six months from the most recent date on the documents of proof that are submitted with the application or your agency's effective date for domestic partner coverage whichever is most current.

New Rejection Messages for Domestic Partners

ADD transactions (both an original ADD and an ADD generated by a CCO) for domestic partners have been programmed to reject when certain situations are present on the Blue Cross file:

1. Both the enrollee and the domestic partner must be unmarried. Therefore, when the enrollee's current marital status is listed as married the ADD will reject with the message "Enr Married Can't Add DP."
2. When an active spouse is listed on the dependent file the Add will reject with the message "Act Spouse Can't Add DP." The spouse will need to be deleted with either a DEL or a CCO to individual, whichever is appropriate, before resubmitting the transaction to add the domestic partner. Note: The enrollee must be listed as divorced, single or widowed before a domestic partner can be added.
3. When an active domestic partner is already listed on the dependent file the ADD will reject with the message "DP Already Exists On File."
4. A social security number is required in order to enroll a domestic partner. Therefore when Item 8 is not correctly completed, the ADD will reject with the message "Invalid DP SSN." The transaction will need to be resubmitted with the correct social security number included in Item 8.

Deleting a Domestic Partner, Retaining Family Coverage

When the enrollee has dependent children who will remain eligible for health insurance the DEL transaction is used to remove a domestic partner either when the relationship ends or when the partner is voluntarily removed. The transaction is completed the same as when any other dependent is deleted from coverage. The effective date will be the date that the relationship ends or the date termination of coverage is requested.

Deleting a Domestic Partner, Changing to Individual Coverage

The enrollee may change to individual at any time, and a CCO is necessary to process this change. when the domestic partner is being deleted due to loss of eligibility the date of event is the date the relationship ends and the effective date is the next day. In all other cases, the date of event is the last day of the month for which family coverage is desired and the effective date is the next day.

Imputed Income

To estimate the imputed income to an enrollee, you should find the correct amount of gross premium from the chart below; from that amount, subtract the difference between the enrollee's individual and family contributions; and multiply by the number of months in the year that the enrollee covers the domestic partner. For example, if your agency offers Option 7 and charges $96.77 for individual coverage and $257.20 for family coverage, and the enrollee covers the domestic partner for 12 months, imputed income would be calculated as follows:

GROSS PREMIUM minus DIFFERENCE IN CONTRIBUTION times NUMBER OF MONTHS equals IMPUTED INCOME

ex. $214.70 - ($257.20-$96.77) x 12 = $651.24

GROSS PREMIUMS FOR INDIVIDUAL COVERAGE

An enrollee with a domestic partner who is eligible for Medicare coverage should receive a Medicare reimbursement for that partner following the same rules used for other dependents. (See section 610 of the Participating Agency Manual for further information on Medicare reimbursement.) when imputed income is calculated for an enrollee in this situation, the amount of the Medicare reimbursements during the year should be added to the calculation as additional imputed income.

Remember, any other benefits that the employer makes available to domestic partners may also generate imputed income to the employee. Employers who offer these other benefits are cautioned to consult with their financial advisors or counsel for a full discussion of the tax implications.