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 contact customer service at 1-888-588-6682.
DSRA Benefit Trust HCTC FAQ
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:
-
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/
-
Print a blank 13441-A form available at https://www.irs.gov/pub/irs-pdf/f13441a.pdf
-
Using the Sample form, complete the 13441-A enrollment form
-
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)
-
Print and complete the DSRA Enrollment form available at www.DSRABenefitTrust.net
-
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) memelig@Benistar.com
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:
-
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/
-
Print a blank 13441-A form available at https://www.irs.gov/pub/irs-pdf/f13441a.pdf
-
Using the Sample form, complete the 13441-A enrollment form
-
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)
-
Print and complete the DSRA Enrollment form available at www.DSRABenefitTrust.net
-
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) memelig@Benistar.com
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.
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.
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.
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:
-
Delphi Salaried retiree
-
Retirement date previous to 4-2-2009
-
Be the Age of 55 to 64
-
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.
Sample 13441-A Forms for various situations can be found below:
2020 open enrollment
HCTC subsidies
HCTC general questions
hctc eligibility
DSRA Benefit Trust Life Insurance FAQ
FAQ #1: My Optional Life coverage will reduce by 10% per year from age 66 to 75, but reductions end whenever a retiree reaches the minimum benefit of $150,000. Will there be a limit to the amount of coverage I can continue?
ANSWER: Yes. If you ' re currently under age 66, the amount of Optional Life Insurance you currently have in effect will begin to reduce by 10% each year starting on January 1 of the year in which you turn age 66; and it' ll continue to reduce by 10% each subsequent January 1 thereafter. However, if your current coverage amount exceeds $150,000, your coverage won ' t reduce below $150 ,000 and you ' ll be able to continue that amount as long as the required contributions are paid.
FAQ #2: I'm under age 66 and my current Optional Life coverage amount is already under
$150,000. What will happen to my coverage when I turn 66?
ANSWER: Nothing. If you ' re under age 66 and currently enrolled in an amount of Optional Life Insurance that is under
$150,000, there will be no reductions when you reach age 66. You' ll be able to continue the amount of coverage you have at that time as long as the required contributions are paid.
FAQ #3: I'm over age 66 and my Optional Life Insurance is reducing under the current plan rules. How does this plan change affect me?
ANSWER: If your Optional Life Insurance has already reduced to an amount below $150,000, your coverage will be "frozen " at the amount currently in force and no further reductions will apply; you ' ll be able to continue the amount of coverage you currently have as long as the required contributions are paid.
If your current coverage amount exceeds $150,000, the 10% reduction will continue until your coverage reaches the $150,000 plan maximum. At that time your coverage will be " frozen" and you will be able to continue this amount of coverage for as long as the required monthly contributions are paid.
FAQ #4: For Dependent Life coverage: Will there be a limit to the amount of Dependent coverage I can continue?
ANSWER: Yes. If you ' re currently under age 70 and enrolled in an amount of Dependent Spouse/Partner coverage that exceeds $150,000, your coverage will be reduced to the plan maximum of $150,000 effective the first of the month following your 70th birthday. You ' ll be able to continue that amount as long as you have an eligible Spouse/Partner and the required monthly contributions are paid.
hSA eligibility
Am I eligible to open a Health Savings Account (HSA)?
FAQ #1: I am covered by a High Deductible Health Plan (HDHP). I am not enrolled in Medicare and I do not have any other coverage through my spouse.
ANSWER: YES, as long as the HDHP meets the definition set by the IRS of an HSA-qualified plan. The DSRA-BT BRONZE and COPPER medical plans meet these requirements.
FAQ #2: I am enrolled in Medicare, can I open a HSA? Am I eligible?
ANSWER: NO. If you are enrolled in Medicare, you may not open a HSA. If you previously opened an HSA, you are able to spend that money, but cannot add additional money.
FAQ #3: I am 65 years old and eligible for Medicare, but have decided to wait to sign up. I am currently covered by a HDHP. ANSWER: YES. Since you aren’t currently enrolled in Medicare and have an HSA-qualified HDHP, you can open an HSA.
FAQ #4: I am covered by Tricare.
ANSWER: NO. At this time, Tricare does not offer a qualified HDHP. Therefore, if you are covered by Tricare, you cannot open an HSA.
FAQ #5: I am enrolled in Medicaid.
ANSWER: NO. You cannot open an HSA if you are currently enrolled in Medicaid. Medicaid is not a qualified HDHP.
FAQ #6: I am covered under my spouse’s plan.
ANSWER: MAYBE. If the plan is a qualified HDHP, you can open an HSA.
FAQ #7: I am already enrolled in an HSA, but my spouse would also like to join it. Can we have a joint HSA?
ANSWER: NO. HSAs are individually owned accounts.
How do I add money to an HSA?
FAQ #1: What are the rules on adding money to an HSA?
ANSWER: You may contribute money into your HSA up to the annual IRS allowable maximum.
FAQ #2: Can the money in an HSA be invested?
ANSWER: YES. The same types of investments permitted for IRAs are allowed for HSAs, including stocks, bonds, mutual funds, and certificates of deposit.
FAQ #3: Who has control over the money invested in an HSA?
ANSWER: As the account holder, you control how the money is invested. You can also choose not to invest your money.
FAQ #4: Will the bank notify me if I’ve exceeded my allowable contribution amount?
ANSWER: NO. It is your responsibility to keep track of the amounts deposited and spent from your account, just like a normal savings or checking account.
FAQ #5: I just started a new job and have enrolled in the HDHP plan; however, it is in the middle of the plan year. Can I still contribute the full annual amount to my HSA?
ANSWER: YES. As long as you are covered by a HDHP by December 1st of the current plan year and remain covered by a HDHP during the entire following year, you may contribute the full annual amount.
FAQ #6: How much can I contribute if I elect the DSRA-BT BRONZE or COPPER medical plan?
ANSWER: The level of coverage in the BRONZE or COPPER plan determines your HSA contribution amount. If you have single coverage, you can contribute up to the single HSA maximum. If you have family coverage (i.e. if you elected Two-Person or Family), you can contribute up to the family maximum, regardless of whether the additional family members are also covered by a non-HDHP.
What are eligible expenses?
FAQ #1: Who decides whether the money I’m spending from my HSA is for a “qualified health care expense”?
ANSWER: You are responsible for spending your HSA money on qualified health care expenses. To view a complete list of eligible expenses, visit the IRS website at www.irs.gov. I have an HSA but no longer have HDHP coverage.
FAQ #2: Can I still use the money for medical expenses tax-free?
ANSWER: YES. You can use money from your HSA to pay for qualified medical expenses for yourself, your spouse, or a dependent without tax penalty. There is no time limit on using the money.
FAQ #3: Can I use my HSA to pay for medical expenses I had before I set up my account?
ANSWER: NO. If you have not yet set up your account, we recommend you do so as soon as possible.
FAQ #4: Can I use my HSA to pay for medical care for a family member?
ANSWER: YES. You can use your HSA money to pay for the qualified medical expenses for yourself, your spouse, or a dependent without tax penalty, even if s/he is not covered by a qualified HDHP.
FAQ #5: Can I use my HSA to pay for medical services provided in other countries?
ANSWER: YES. Make sure, however, that the medical services you are receiving are eligible health care expenses. Elective surgery, for example, may not be considered a health care expense.
FAQ #6: Can I pay my health insurance premiums with my HSA?
ANSWER: MAYBE. You can only pay your health insurance premiums with money from your HSA if you are collecting federal or state unemployment benefits, or you have COBRA continuation coverage through a former employer. The medical plans offered through the Delphi Salaried Retiree Association (DSRA) are not considered COBRA continuation. Thus, you may not pay your health insurance premiums with money from your HSA.
FAQ #7: How do I use my HSA to pay my doctor at the time of service?
ANSWER: With an HSA plan, you should not pay your doctor at the time of service, and your insurance card should read “$0 copay” on the front. Instead, wait for the doctor’s office to bill your health insurance company, and you will then receive a bill for your visit. Then you can pay your doctor using the funds from your HSA.
After I open my HSA, what happens to the money?
FAQ #1: After I open my HSA, what happens to the money? Does unused money in an HSA rollover year after year?
ANSWER: YES. The money in an HSA automatically rolls over each year. You won’t lose your money if you don’t spend it within the year.
FAQ #2: What happens to the money in my HSA after I turn 65?
ANSWER: When you enroll in Medicare, you can use your HSA to pay Medicare premiums, deductibles, copays, and coinsurance under any part of Medicare; but you cannot use your account to purchase a Medicare supplemental insurance or “Medigap” policy. You can also continue to use your account tax-free for out-of-pocket health expenses.
FAQ #3: What happens to the money in my HSA if I switch back to traditional PPO coverage?
ANSWER: The money that is already deposited into your HSA will remain in your account until it is gone. You may continue to use the HSA money for eligible expenses; however, you are no longer allowed to add money to your HSA.
FAQ #4: What happens to the money in my HSA when I die?
ANSWER:When you first open your HSA, you will be asked to select a beneficiary. The beneficiary you choose will receive the money left in your HSA when you die.