Job & Family Services Office of Child Support
Office of Child Support - Health Plan Administrators



If you are a health plan administrator …

Your role in enrolling children in available medical coverage is invaluable. Once enrolled, children who might not otherwise be covered under a medical insurance plan can receive needed medical attention.

Pursuant to section 3119.37 of the Ohio Revised Code, health plan administrators are required to complete and comply with a National Medical Support Notice (NMSN) and the accompanying JFS 03377-Employer/Health Plan Administrator Health Insurance Verification Request sent by an employer. Additional pertinent sections of the Revised Code include 3119.42, 3119.421, 3119.422 and 3119.43.

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A health plan administrator (HPA) is required by 29 U.S.C. 1169(a) to provide benefits in accordance with a qualified medical child support order (QMCSO). Upon receipt of a NMSN, a HPA is required to determine if the NMSN meets QMCSO requirements. The HPA is to deem the NMSN a QMCSO if it specifies the participant's name and last known mailing address and the name and mailing address of each alternate recipient covered by the order, except the name and mailing address of an official of a Child Support Enforcement Agency may be substituted for the address of the alternate recipient.

The Department of Labor has issued a Compliance Guide for Qualified Medical Child Support Orders (QMCSOs) to help employers, health plan sponsors and service providers understand the health benefits law regarding QMCSOs, including the revisions resulting from the development of the NMSN. The DOL Guide (link below under Links & Resources section) answers general questions about QMCSOs, NMSNs, and the role of the child support enforcement agency in obtaining available health care coverage and medical care for the children. Employers and health care plan administrators will find the information useful in understanding the rights and obligations of those involved in child support proceedings and those responsible for administering health care plans.

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Other Responsibilities  

The HPA is also required to:

  • Immediately enroll the child(ren) in plan if there are no obstacles (such as a waiting period, more than one plan option etc.)
  • If there is more than one plan option available to the employee, notify the CSEA within 20 days. If the CSEA does not respond with the custodial parent's selected option, insurer will select a default option.
  • If Part B, Response 2 is checked, notify the non-custodial/participant named in the notice, each named child, and the custodial parent that coverage of the child(ren) is or will become available [notification of the custodial parent will be deemed notification of the child(ren) if they reside at the same address].
  • Furnish the custodial parent a description of the coverage available and the effective date of the coverage, including, if not already provided, a summary plan description and any forms, documents, or information necessary to effectuate such coverage, as well as information necessary to submit claims for benefits.
  • Within 40 business days after the date of the NMSN complete and return the NMSN to the issuing CSEA.

The completed NMSN/JFS 03377 will advise the CSEA:

  • That the children will be enrolled.
  • The effective date of coverage.
  • The need to select a coverage option.
  • That the participant is subject to a waiting period and will be enrolled when coverage is available.
  • That the notice does not qualify as a QMCSO, so the children will not be enrolled.

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Health Insurance Portability and Accountability Act (HIPAA) restrictions have no impact on your obligation to report the information requested on the National Medical Support Notice or to enroll the minor child(ren) of the employee named in your health coverage plan. A covered entity may disclose otherwise protected health information to the extent that disclosure is required by law, consistent with that law (45 Code of Federal Regulations 164.512(a)).

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Other Information  

According to section 3119.422 of the Ohio Revised Code, HPAs are not required to accept for enrollment any child who does not meet the underwriting standards.
Please note that failure to obtain health insurance coverage as required may lead to contempt penalties according to section 3119.43 of the Ohio Revised Code.

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Health Plan Administrator Links and Resources  

View the DOL Compliance Guide at: https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/publications/qualified-medical-child-support-orders.pdf.

View a copy of the National Medical Support Notice at: http://www.odjfs.state.oh.us/forms/results1.asp?stype=FORM_NUM&searchPar=OMB%.

View a copy of the accompanying JFS 03377-Employer/Health Plan Administrator Health Insurance Verification Request at:http://www.odjfs.state.oh.us/forms/results1.asp.
View information regarding the NMSN employer responsibilities on the Medical Support Overview page at: http://www.jfs.ohio.gov/Ocs/employers/medsupp.stm.

View the Ohio Medical Support related frequently asked questions and answers at: https://jfs.ohio.gov/Ocs/OCSFAQs.stm.

View the Medical Support related Ohio Administrative Code rules at: http://codes.ohio.gov/oac/5101%3A12-47.

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 Last Updated 08/16/2018