ADMINISTRATIVE INFORMATION

Continuation of Coverage

The following plans are covered under COBRA:

• Medical, Dental, Vision and EAP Plans
  In accordance with the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), Valassis provides you and your eligible dependents the opportunity to continue your participation in a Valassis-sponsored medical, dental, vision and/or EAP plan under certain circumstances. These circumstances are called qualifying events.

• Health Care Flexible Spending Account
  You may, under certain circumstances, be eligible to continue your participation in a Health Care Flexible Spending Account (FSA) by making after-tax payments. Health Care FSA continuation under COBRA is generally available only if you have unclaimed money remaining in your account when the qualifying event occurs. If you have already claimed all the money you contributed to your account, you will not be eligible to continue participation under COBRA.
  
  You may not continue your Dependent Care FSA participation under COBRA.

Eligibility for COBRA
If you are enrolled in a Valassis-sponsored medical, dental, vision plan, a Health Care FSA or the EAP, you become eligible to continue your coverage through COBRA when one of the following qualifying events causes you to lose coverage:

• Your employment ends for any reason other than gross misconduct,
• The end of a period during which your coverage was continued for one of the following reasons: leave of absence, disability or an occupational injury or illness covered by Workers’ Compensation, or
• Your scheduled work hours are reduced so that you are no longer eligible for coverage.

For Your Spouse
Your covered spouse may be eligible to continue coverage through COBRA if his or her coverage ends because:

• You become eligible for COBRA,
• You become legally separated or divorced, or
• You die.

For Your Dependent Children
Your covered dependent children may be eligible to continue coverage through COBRA if their coverage ends for any of the reasons listed under For Your Spouse above. Also, if your dependent children no longer meet the plan’s definition of an eligible dependent (for example, a dependent child over age 19 is no longer a full-time student), they may be eligible for COBRA continuation coverage.

How Long COBRA Coverage Lasts
Coverage may continue for 18 months or 36 months depending on the type of qualifying event.

Continuation for 18 Months
You and your covered family members may continue medical, dental, vision and/or EAP coverage under COBRA for up to 18 months if your coverage ends because of any of the following qualifying events:

• Your employment ends for any reason other than gross misconduct,
• The end of a period during which your coverage was continued for one of the following reasons: leave of absence, disability or an occupational injury or illness covered by Workers’ Compensation, or
• Your scheduled work hours are reduced so that you are no longer eligible for coverage.

You may continue Health Care FSA participation until December 31 of the calendar year in which any of the above qualifying events occurs.

Continuation for 36 Months
Your covered spouse and covered dependent children may continue medical, dental, vision and or EAP coverage for up to a total of 36 months if coverage ends because of any of the following qualifying events:

• You become legally separated or divorced, or
• You die.

Your covered dependent children may also continue medical, dental and vision coverage for up to a total of 36 months if they lose coverage because they no longer qualify as eligible dependents.

Special Notice: Certification of Coverage
Valassis must automatically provide written certification of prior coverage to each person who loses coverage under an Valassis-sponsored medical plan. Information on specific benefits must also be provided if requested by another health plan—for example, your new employer’s plan.

You may need to show this certification in order to enroll in another health plan, especially if that plan limits coverage for certain preexisting health conditions. Under a federal law called the Health Insurance Portability and Accountability Act of 1996 (HIPAA), a health plan cannot impose preexisting condition exclusions for more than 12 months (18 months for a late enrollee), and that exclusion period must be reduced by your prior health coverage period.

In Case of Disability
If the Social Security Administration determines that you or a covered family member was totally disabled under Title II or Title XVI of the Social Security Act at the time of the qualifying event, or during the first 60 days of the 18-month continuation period, the continuation period will be extended to 29 months. Any covered family member may elect to extend COBRA coverage to 29 months, even if the disabled person does not make this election. Please note the premium charged during this extension can be up to 150% of the applicable group rate. You must send a copy of the determination notice to the COBRA administrator before the end of the initial 18-month period and within 60 days of the date of the notice. You must also notify the COBRA administrator within 30 days of a determination that the person is no longer considered disabled.

Multiple Qualifying Events
If your spouse or dependent children experience more than one qualifying event, they may be eligible for an additional period of continued coverage, not to exceed a total of 36 months from the initial qualifying event.

For example, suppose you terminate employment on January 1, 2008, and you are eligible to continue coverage for 18 months (until June 30, 2009). Your child turns 25 and ceases to be an eligible dependent (a second qualifying event) on December 31, 2008. Your child is eligible to extend coverage, up to a maximum of 36 months from the date of the original qualifying event. In this case, your child may continue coverage through December 31, 2011, which is 36 months from January 1, 2008, the date of your termination of employment (the original qualifying event).
To be eligible for extended coverage after a second qualifying event, you must notify the COBRA administrator within 60 days of the date of the second qualifying event.

COBRA coverage ends if any of the following occurs:

• The COBRA participant fails to make a required contribution within 30 days of the date it is due,
• Valassis stops offering medical, dental, vision, Health Care FSA and/or EAP coverage to all associates,
• The COBRA participant becomes eligible for coverage under another group medical or dental plan after the election of COBRA coverage (If the other plan limits coverage of a preexisting condition, COBRA coverage may be continued in certain circumstances), or
• The COBRA participant becomes entitled to Medicare after the election of COBRA coverage.

For the Health Care FSA, participation under COBRA ends on the sooner of December 31 of the calendar year in which the qualifying event occurs or the date that any of the events listed above occurs.

Type of Coverage
The medical, dental, vision and Health Care FSA plans available to you through COBRA are the same as the plans offered to active Associates. Any changes to the plans for active Associates will automatically apply to your and your dependents’ COBRA coverage.

How to Continue Coverage
If your qualifying event is termination of employment or a reduction in your work hours, Valassis’ COBRA administrator will automatically notify you and your covered dependents of your right to continue coverage. If you die, Valassis’ COBRA administrator will automatically send the COBRA notification to your covered dependents.

Valassis will not, however, be aware of all qualifying events—for example, a divorce or a child no longer qualifying as a dependent. It is your responsibility to notify Valassis within 60 days of the qualifying event. A COBRA notice will be sent to your covered family members within 14 days of the date Valassis receives notification of your qualifying event. This COBRA notice will explain their right to continue coverage.

You and/or your covered family members have 60 days from the date coverage ends following a qualifying event or the date of the COBRA notice, whichever is later, to elect to continue coverage. If you do not elect COBRA within 60 days, you will not be eligible to continue coverage through COBRA, and your coverage will end according to the plan’s normal provisions.

If you or a dependent initially waives COBRA coverage, you may revoke that waiver and elect COBRA coverage within the original 60-day election period. In this case, COBRA coverage will begin on the date the election is received by the COBRA administrator (not retroactive to the date of the qualifying event).

Your Cost
You will receive monthly bills for your COBRA coverage from the COBRA administrator. You must pay your bill in full no later than 30 days from the due date. Failure to pay on a timely basis will result in cancellation of coverage. Click here to view the 2009 COBRA costs.

Medical, Dental and Vision Coverage
You and your covered dependents are required to pay the full cost of medical, dental, vision and EAP coverage, which includes Valassis’ full cost for providing your coverage, plus an additional 2% of that amount to cover the cost of administrative service. If Valassis’ cost for providing coverage changes, your cost will also change.

Health Care Flexible Spending Account
If you are eligible to continue contributing to a Health Care FSA under COBRA, you must do so on an after-tax basis. You are also required to pay an administrative fee to Valassis for continuing your participation. This fee is equal to 2% of your contribution and is not reimbursable.

Changing Your COBRA Coverage
While you are continuing coverage under COBRA, you and your covered dependents may change your medical, dental, vision and EAP coverage during the annual enrollment period. If you did not elect COBRA during the 60-day election period, you may not elect it during a subsequent annual enrollment period. Because Health Care FSA participation under COBRA ends on December 31 of the calendar year in which the qualifying event occurs, you may not elect to continue participation in a Health Care FSA during annual enrollment.

You may also make certain qualified status changes to your coverage, such as:

• Adding a new spouse or a newborn or newly adopted child (or a child that is placed for adoption) to your medical, dental and vision coverage,
• Adding an eligible dependent who loses other medical, dental or vision coverage,
• Adding a dependent to your medical, dental or vision plan if required by a family relations judgment, decree or order, such as a Qualified Medical Child Support Order, and
• Changing your medical plan if you are covered by a managed care plan and move out of its coverage area.

You must call the COBRA administrator within 31 days of the event that caused the status change in order to change your coverage while on COBRA. Your change in coverage will be effective on the date of your status change, provided you call the COBRA administrator within 31 days of the status change. In the case of a domestic relations judgment, decree or order, the child will be covered on the date specified in the judgment, decree or order.

If you are continuing participation in the Health Care FSA under COBRA, you may submit eligible expenses for your new spouse or newborn or newly adopted child for reimbursement from your account.

The COBRA administrator for Valassis Communications, Inc. and NCH associates is Corporate Benefits at 734-591-3000. The COBRA administrator for Valassis Direct Mail and Sales and Marketing is Ceridian at 800-877-7994.

Newborn and Adopted Children
If you have a baby, adopt a child or a child is placed with you for adoption, your child will be a qualified beneficiary with independent election rights and multiple qualifying event rights. A parent or legal guardian can make COBRA elections on behalf of a minor child. Coverage will be effective on the date of birth, adoption or placement for adoption, provided you enroll the child within 31 days of birth, adoption or placement for adoption.

If You Become Entitled to Medicare
If you become entitled to Medicare while you are an active Associate and you later experience a qualifying event (for example, terminate your employment), you and your dependents may be eligible for continued coverage when the qualifying event occurs. In this case, your covered dependents may be eligible to continue coverage for up to 36 months from the date of your Medicare entitlement or 18 months from the date of your qualifying event, whichever is later.

If you become entitled to Medicare after you elect to continue coverage under COBRA, your continued coverage will end on the date of your Medicare entitlement. Your covered dependents, however, may be eligible for up to 36 months of continued coverage from the date of the original qualifying event.

	Plan Administration Qualified Medical Child Support Order Continuation of Coverage Your Rights as a Plan Member Filing a Claim Other Information Numbers, Addresses & Links

Summary Plan Description
The Valassis Benefits Handbook serves as the Summary Plan Description for most benefits. A 2008 handbook will be issued soon.