Wednesday, February 16, 2011

NEW YORK HEALTH CONTINUATION COVERAGE EXTENDED TO 36 MONTHS AND OTHER STATE MINI-COBRA RULES

Charles C. Shulman, Esq., LLCEmployee Benefits, Employment & Executive Compensation Law
http://www.ebeclaw.com/  – http://www.employeebenefitslaw.info/
NJ Office: 632 Norfolk St., Teaneck, NJ 07666
NY Office:  345 7th Ave., 21 Fl., NY, NY 10001
Admitted in NJ & NY
Tel - 201-357-0577 (rings in NJ, NY & on cell)
Fax - 201-836-4847 cshulman@ebeclaw.com

EBEC (Employee Benefits / Executive Compensation) Law Update

January 5, 2010
NEW YORK HEALTH CONTINUATION COVERAGE EXTENDED
TO 36 MONTHS AND OTHER STATE MINI-COBRA RULES
           
            New York State recently passed a law that extends continuation health coverage to 36 months.  Thus, group insurance plans that are subject to New York insurance law will have to offer continuation coverage for a total of 36 months, even though under the Federal COBRA law continuation coverage on termination of employment would only be required for 18 months.

            COBRA 20-Employee Requirement.  Under Federal COBRA continuation coverage rules, employers with 20 or more employees on a controlled group basis must offer employees and beneficiaries the election to continue group health plan coverage (at up to 102% of company cost) upon the occurrence of certain events such as termination of employment.[1]

State Mini-COBRA Laws.  About 40 states have continuation health coverage requirements for insured group health plans of small employers that would apply even to small employers (e.g., with two or more employees) who do not have the 20 employee threshold to trigger Federal COBRA.  Some states provide for continuation coverage for the full 18 months, while others provide for continuation coverage for lesser periods.[2]  These state statutes are sometimes referred to as mini-COBRA laws. 
v  State mini-COBRA laws are insurance laws and apply only to insured group health plans but not to self-insured plans, and in fact state laws cannot regulate self-insured plans because of the ERISA preemption rule, as discussed below. 
New York Extension of Continuation Coverage to 36 Months.  The NYS continuation coverage mini-COBRA law[3] was expanded in June 2009 to require that insured group health plan continue coverage for a total of 36 months rather than just the 18 months available on termination of employment under COBRA.[4]  California has had this 36 month extension since 2003.[5]   
v  The NYS Insurance Dept. view is that the original NYS mini-COBRA continuation coverage election at the time of termination will suffice for the coverage to extent to 36 months, unless coverage is interrupted (e.g., because of failure to pay premiums). See bullet after next full paragraph.  
v  If continuation coverage has ended prior to July 1, 2009, there would be no entitlement to an additional 18 months.  See below regarding special enrollment period for coverage that has ended between July 1 and November 1, 2009. 
Extension Can be at End of 18 Month Federal COBRA.  The NYS extended continuation coverage rule also provides that even if the participant was receiving Federal COBRA continuation coverage for 18 months (under an insured plan), the participant must be offered the opportunity to continue coverage for an additional 18 month (up to 36 months from termination) under the N.Y. mini-COBRA law.[6]
v  If Federal COBRA coverage is in effect on or after November 1, 2009 (or the renewal date of the policy after June 30, 2009), it would appear from NYS Insurance Department FAQs that the state continuation coverage will continue automatically.   NYS Insurance Law § 3221(m)(6), however, states that when COBRA ends the participant will be given the opportunity to continue NYS coverage, which implies that a new election at that time.  Some practitioners are of the view that the NYS continuation coverage election must be made at the time of termination of employment, and cannot be elected at the expiration of the 18 month period (unless the special enrollment period is still in effect).  It is likely that employers will tie the initial COBRA election together with a New York election, so that there is no question that the 36 months will be available and so that there is no risk that the election has been made too late.  Absent further guidance from the NYS Insurance Department, those who are on COBRA during the special enrollment period discussed below would be wise to specifically communicate their intention to the plan administrator to be continued in the additional New York 18 months extension.   The interaction of the Federal COBRA election and the NYS continuation coverage election is not clear and will likely be addressed by the NYS Insurance Dept.
v  This state wrap-around benefit for Federal COBRA for disability (which is 29 months, but with up to a 150% premium), would be extended an additional 7 months at the 102% premium rate.[7]
NY Continuation Coverage Extension Effective Earlier of 11/1/09 or Amendment to Policy on or after 7/1/09.   The NYS extended continuation coverage law from June 2009 was originally effective for all policies issued, renewed or amended on or after July 1, 2009.[8]  However, an amendment to that law in November of 2009 accelerated the effective date of the NYS extended continuation coverage to no later than November 1, 2009 regardless of date of renewal of contract.[9] 
Special One-Time Enrollment Period for 60 Days From Notice of New Rule.  The November 2009 amendment provides that for those whose COBRA or New York continuation coverage ended between July 1, 2009 and Nov. 1, 2009, there is a 60 day special enrollment period from the date notice of this new rule is provided to participants, during which theNew Yorkextension can be elected.[10]  If no notice is provided, the special enrollment period will end on May 19, 2010.  Elections would be effective within 30 days of election and payment and would apply prospectively. [11]
NY Mini-COBRA (Like Other State Mini-COBRA Rules) Not Applicable to Self-Insured Plans Even if Have Stop-Loss Coverage.  TheNew Yorklaw regulates insurance companies, and in the case of self-insured plans the N.Y. statute would not apply.[12]  Also, ERISA would generally preempt state laws (even if they purport to regulate insurance) with respect to self-insured plans.[13]  Most courts apply this ERISA preemption even where the self-insured plan has stop-loss coverage.[14] 
v   The New York mini-COBRA would not apply to a dental-only, vision-only or prescription-only plan.[15]
v  The NYS continuation extension law applies to insurance contracts delivered in NYS (e.g., employer in NYS), and would presumably apply even to out of state employees.
v  Employers with different types of plans may desire to have parity among all its plans and may offer the additional 18 months even for their self-insured plans.

            COBRA Temporary 65% Subsidy Applicable to State Mini-COBRA Rules. 
The February 2009 stimulus act as amended in December 2009[16] includes a 15 month government subsidy of 65% of the COBRA continuation health coverage premiums for employees who were involuntarily terminated between Sept. 1, 2008 and February 28, 2010.  The subsidy applies not just to Federal COBRA but also to state mini-COBRA laws.[17]

             IRS Circular 230 Disclosure: To ensure compliance with requirements imposed by the IRS, we inform you that any U.S. federal tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter that is contained in this document.


[1]       See ERISA § 601(b) & Code § 4980B(d) regarding the 20-employee requirement.
[2]       A handful of states extend the mini-COBRA coverage for the full 18 months that would be available under Federal COBRA on termination (Colorado, Connecticut, Florida, Kentucky, Maryland, Massachusetts, Minnesota, New Hampshire, New Jersey, Nevada, North Carolina, Rhode Island, West Virginia and Wisconsin).  See below that California and New York offer more than 18 months.  Some states extend the state-COBRA for only 12 months (Illinois, Louisiana, Maine, Mississippi, Ohio, South Dakota and Wyoming), some for nine months (Iowa, Missouri, North Dakota, Oregon, Pennsylvania and Virginia), some for six months (Kansas, New Mexico, Nebraska, South Carolina, Texas, Utah and Vermont), some for four months (Arkansas and Oklahoma) and some for three months (Georgia, Tennessee and the District of Columbia).  About 10 states do not have mini-COBRA rules (as of 2009, Alabama, Alaska, Arizona, Delaware, Hawaii, Idaho, Indiana, Michigan, Montana and Washington).  See, Hamburger, “Mandated Health Benefits - The COBRA Guide,” ¶ 2020 (Thompson, updated Nov. 2009).  See, also, “The Guide - Health Insurance for the Unemployed - 2009,” at www.healthinsurancefinders.com/unemployed/guide.  These state rules change often, so one should confirm for latest changes.
[3]       Under New York Insurance Law § 3221(m), an insurer’s group health policy that is not covered under COBRA because the employer has less than 20 employees must still provide continuation coverage, which basically mirrors the Federal COBRA rules.
[4]       NYS Insurance Law § 3221(m)(4) as amended by Chapter 236 of Laws of NY 2009, S.5471 (July 29, 2009), codes.lp.findlaw.com/nycode/ISC/32/3221.
[5]       California has a state mini-COBRA law for employers with two or more employees but without the 20 employees needed for Federal COBRA coverage.  California amended its mini-COBRA rule effective Jan. 1, 2003 to require (like New York has done in 2009) that group health plans provide for 36 months of continuation health coverage for any COBRA qualifying event.  California Insurance Code § 10128.27.  In addition, if the Federal 18 months of COBRA on termination are used up, the law requires the group health plan to offer an additional 18 months of continuation health coverage.  Id.  Up to 110% of the premium cost may be charged.  This rule would apply only to insured plans.  Self-funded plans would not be subject to state insurance law, and also have ERISA preemption.
[6]       N.Y. Insurance Law § 3221(m)(6) as amended.
[7]       NYS Insurance Dept. Circular Letter No. 23 (Sept. 30, 2009) - www.ins.state.ny.us/circltr/2009/cl2009_22.htm. 
[8]       Chapter 236 of Laws of NY 2009 (July 29, 2009), www.ins.state.ny.us/cobra/S5471_36_ext_final.pdf. 
[9]       Chapter 498 of Laws of NY 2009 (Nov. 19, 2009),  open.nysenate.gov/legislation/api/html/bill/S66006.
[10]     N.Y. Insurance Law § 3221(m)(8), added by November amendment.
[11]     Id.
[12]     N.Y. Insurance Department FAQs - State Continuation Coverage Extension to 36 Months, www.ins.state.ny.us/cobra/cobra_ext_36.htm.  
[13]     Although the “savings clause” of ERISA § 514(b)(2)(B) provides that laws regulating insurance are not preempted by ERISA, with regard to self-funded plans there would be preemption because under ERISA § 514(b)(2)(B) (the “deemer clause”) states may not “deem” self-funded plans to be insurers.
        Even with regard to insured plans, state laws that purport to regulate conduct with respect to the employer rather than the insurance company, or laws that are overbroad and apply to insured and self-insured plans, may be preempted by ERISA.  See, Kentucky Association of Health Plans, Inc. v. Miller, 538 U.S. 329 (2003) (for a state law to regulate insurance and not be preempted, the law must be specifically directed to entities engaged in insurance, and the state law must substantially affect the risk pooling arrangement with the insurance company).   See, also, Duclos v. General Dynamics Corp. , 12 E.B.C. (BNA) 2648 (D.R.I. 1990) (Rhode Island statute requiring certain divorced spouses to be granted continuation health coverage without additional premiums was preempted by ERISA and the “savings clause” would not apply because the law does not regulate the business of insurance or the benefits under the policy, but rather the conduct with respect to the employer; also the statute as it purported to apply to insured and self-insured plans was invalid); Thompson v. Bridgeport Hospital, 2001 WL 823130 (Super. Ct. Conn. 2001) (claims against employer under a Connecticut continuation health coverage law was preempted by Federal law; Federal and not state courts have exclusive jurisdiction over COBRA notice penalty claims); DOL Adv. Op. 96-04A (Feb. 22, 1996) (that a Connecticut COBRA statute’s requirement that the employer must give notice before canceling a policy would be preempted by ERISA since that part of the rule did not regulate insurance).
[14]     See, e.g., Bill Gray Enterprises Employee Health and Welfare Plan v. Gourley, 248 F.3d 206 (3d Cir. 2001) (purchase of stop-loss coverage does not cause self-insured plan to be an insurance company under savings clause; stop-loss insurance not designed to insure individual participants but to reimburse plan after plan makes benefit payments); Bank of Louisiana v. Aetna U.S. Healthcare Inc., 459 F. 3d 610 (5th Cir. 2006), superseded on other grounds, 468 F.3d 237, cert. denied, 127 S. Ct. 1826  (2007) (employer's claim against insurer which was also stop-loss insurer not preempted by ERISA); American Medical Security, Inc. v. Bartlett, 111 F.3d 358 (4th Cir. 1997) (Maryland insurance law requiring certain mandated benefits and defined stop-loss policies to exclude policies that had specific or aggregate attachment points below certain minimum levels; court held that state effort to regulate content of self-funded plans through the regulation of stop-loss contracts was preempted by ERISA); Bergin v. Wausau Insurance Companies, 863 F. Supp. 34 (D. Mass. 1994) (Massachusetts law requiring that divorced spouse have continuation coverage was preempted with respect to self-funded plans, and stop-loss coverage did not cause it to be like insured plan since no single claim exceeded its retained obligation); Thompson v. Talquin Bldg. Products Co., 928 F.2d 649 (4th Cir. 1991) (health plan was self-funded even though it purchased stop-loss insurance, emphasizing that plan remained directly liable to participants and insurance did not cover employees directly); United Food & Commercial Workers & Employers Arizona Health & Welfare Trust v. Pacyga, 801 F.2d 1157 (9th Cir. 1986) (ERISA preempts state anti-subrogation law for self-insured plan even though it had stop-loss coverage, since the policy proceeds were payable only to the plan); DOL Adv. Op. 91-05A (Jan. 14, 1991) (stop-loss coverage does not make a self-funded plan insured, and therefore is still preempted by ERISA).  But see Northern Kare Facilities/Kingdom Kare, LLC v. Benefirst, LLC, 344 F. Supp. 2d 283, (D. Mass. 2004) (claim that stop-loss insurers breached their contract with health plan sponsor by refusing to make stop-loss payments to plan was not preempted by ERISA since there judicial enforcement of stop-loss insurance contract would not be an alternative enforcement mechanism to ERISA).
[15]     N.Y. Insurance Department FAQs - State Continuation Coverage Extension to 36 Months, www.ins.state.ny.us/cobra/cobra_ext_36.htm.  
[16]     American Recovery and Reinvestment Act of 2009, (the “Stimulus Act”), enacted on Feb. 17, 2009, § 3001, www.dol.gov/ebsa/pdf/COBRAPremiumReductionProvision.pdf , as amended by the Department of Defense Appropriations Act for Fiscal Year 2010, Dec. 19, 2009 (the “DOD Act”), § 1010,  www.dol.gov/ebsa/cobra/COBRAPremiumReductionProvisionExtension.html .   See EB/EC Law Update – Extension of Federal COBRA Subsidy (Dec. 27, 2009).
[17]     Some states have provisions that specifically apply the Federal COBRA subsidy to state continuation coverage (e.g., California, Colorado, Connecticut, Georgia, Illinois, Kansas, Maine, Maryland, Massachusetts, Minnesota, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, Texas, Utah, Virginia, Wisconsin and District of Columbia).  Also, certain state insurance departments provide guidance that specifies that the Federal COBRA ARRA subsidy applies to the state continuation coverage (e.g., Kentucky, New Hampshire, New Jersey and South Dakota).  See Hamburger, “Mandated Health Benefits – The COBRA Guide” ¶ 2040 (Thompson, updated Nov. 2009).

93 comments:

  1. I think even if they are just small employers, they still need to give their employees the necessary medical and dental health provisions. Or their employee should at least have a sponsored visit to the Omaha dentist at least twice a year.

    ReplyDelete
  2. I would highly recommend this firm for accident with limited tort. Manny helped make the process of my claim easier. He made sure I was updated throughout the entire process and answered any questions I had. The staff was very knowledgeable and understanding, I'm sure glad I made the right choice to. I highly recommend him Great service! worst lawyers

    ReplyDelete
  3. Health has dependably been a best issue among the general population everywhere throughout the world and they have been stressing over their health and the health of their friends and family for a very long time.side effects of clen

    ReplyDelete
  4. The WHO meaning of health is doubtful (no one, not in any case the most ardent wellite, appreciates "finish physical, mental and social prosperity," in any event only one out of every odd day). Methyl-Life

    ReplyDelete
  5. They are cooperating to assemble information on the best methodologies, at that point will share that data and urge different suppliers to receive the best techniques framework. benefits

    ReplyDelete
  6. Its a great pleasure reading your post.Its full of information I am looking for and I love to post a comment that "The content of your post is awesome" Great work. criminal defense attorney

    ReplyDelete
  7. At some point and a few thousand dollars later I had concluded that I would scan for normal cures or else I would need to kick the bucket. here

    ReplyDelete
  8. and it's significantly less demanding to achieve those little strides than the ones considerably more distant away.
    bulletproof collagen

    ReplyDelete
  9. The contrasts between these two incorporate the decision offered by the suppliers, the measure of bills the approach holder needs to pay and the administrations secured by the arrangement. As you can simply hear there is no extreme or best arrangement for anybody.psicologo avezzano

    ReplyDelete
  10. Apart from the representatives it is likewise important to clarify the health advantage wants to the health advantage administrators with the goal that they can disclose it to the workers to.https://asbestoscancer.org/stage-four-mesothelioma/

    ReplyDelete
  11. The last is the thing that you get when you put astutely in your own prosperity. best light therapy lamp reviews

    ReplyDelete
  12. At the point when mineral enhancements are taken in non chelated frame they are typically consequently chelated in the stomach amid absorption. Turmeric supplement plus

    ReplyDelete
  13. . There will never be been a period in history when so much has been accessible to us to have the capacity to get into the best physical and mental shape, any age before us has ever observed.winstrol benefits

    ReplyDelete
  14. The home grown healthcare items fortify the safe arrangement of the body and also it contains a few wholesome segments.
    adrian vance

    ReplyDelete
  15. Fee for Service (FFS) Plans. The FFS plan is the conventional type of individual health protection. It works just - you get the care you require, at that point you're repaid for a level of the expense.beta alanine side effects

    ReplyDelete
  16. When you see perceptible change, it is very likely that a health and fitness fixation will end up apparent and you will begin to carry on with your life around your fitness when quite a long time ago you attempted to fit your health kick in around your past way of life.health guest post sites

    ReplyDelete
  17. Presently the inquiry is what is a cardiovascular movement? Bouncing rope, running, swimming, strolling, step heart stimulating exercise, and so on all these are cardiovascular exercises.URL

    ReplyDelete
  18. Data asked for may incorporate your health history, family health history, diet, and exercise. Contingent upon the health care proficient you are seeing, other data might be asked.wellphora cbd oil

    ReplyDelete
  19. This is undisputed logical reality. Plainly there's significantly more to building up an entire nourishing arrangement than simply checking calories, however this is the initial phase in understanding. tren enanthate 200

    ReplyDelete
  20. There you will discover individuals making inquiries or perhaps for explicit subjects that you could post about. health blogs that accept guest posts

    ReplyDelete
  21. Home health care programs offer a variety of administrations. These administrations are done in the support of the patients claim home. Home health designs are ordinarily checked by a specialist. juicing tips

    ReplyDelete
  22. Increasingly, children in schools are demonstrating serious mental health problems. This may be happening as a result of the the recent economic downturn. Problems of anxiety, depressions, anger, impulse control, CBD for anxiety and depression, substance abuse, physical and sexual abuse histories, and family dysfunction are seen routinely by teachers administrators and other professionals. Children in middle and secondary schools are particularly affected. School psychologists and counselors attempt to deal with these problems but are more skilled in handling learning problems and less able to deal with emotional issues.

    ReplyDelete
  23. Even in "real-life" it seems that we, as depicted in this movie, simply believe that taking a pill can give us all the solutions to our needs. buy humatrope online

    ReplyDelete
  24. An individual may encounter health even at an analyzed ailment and great health positively affects both the protection from illness and the capacity to recoup and recuperate from damage and malady.Living Well Counselling Calgary

    ReplyDelete
  25. In a great deal of the exchanges I have with customers, there are a few articulations they use: "I as of now have inclusion, so I won't be influenced by ObamaCare," or "I'll simply keep my grandfathered health protection plan," and the last one - and this one I can give them a smidgen of breathing space, since part of what they're stating is valid - is "I have amass health protection, so I won't be influenced by health care change." Extreme weight loss plan

    ReplyDelete
  26. This pills need to go for the test before come to market so w can get guarantee results.

    ReplyDelete
  27. Mental health is so much important. For this celery juicer can be quite effective as per I know.

    ReplyDelete
  28. You can do some exploration to locate the best items for your necessities so you can get the best help for your wellbeing.

    Nano Hearing Aids Reviews

    ReplyDelete
  29. Hopefully you are getting an awesome reaction. For celery juicer you can count on it. See you other side.

    ReplyDelete
  30. Awesome site! You’ve some quite interesting posts.. Nice background as well haha. Keep up the nice work, Ill make sure to come across to see really your page! Home Cleaning Abu Dhabi Mussafah

    ReplyDelete
  31. In picking this sort of health insurance plan, it is vital that one should peruse the approach depiction giving extraordinary spotlight on secured administrations.nutraceutical manufacturer

    ReplyDelete
  32. This comment has been removed by the author.

    ReplyDelete
  33. The study went on to show that those individuals sleeping in new beds reported significantly less pain. See here

    ReplyDelete
  34. There's a great deal of misconception about what is new with ObamaCare, and something that I've seen in dialogs with customers, is that there's a basic arrangement of legends that individuals have grabbed about social insurance change that simply aren't valid. curcuminoids

    ReplyDelete
  35. A body health check up fundamentally involve pathology (blood and pee), imaging (x-beam and ultra-sonography), lungs work test and heart stress test. These tests ought to preferably be done in a licensed research center or an emergency clinic which is outfitted with the best demonstrative devices.Health

    ReplyDelete
  36. Also, restorative expenses are raising high as can be, medical procedures or task, test and drugs and so on shoot up your bills like anything.Health List

    ReplyDelete
  37. Your work is truly appreciated round the clock and the globe. It is incredibly a comprehensive and helpful blog. Health

    ReplyDelete
  38. Note down everything that you eat for about fourteen days, including the amount. Acheter des amandes

    ReplyDelete
  39. The key is, you should admirably gauge the advantages. Particularly that not among these plans will pay though the budgetary harms related with your couldn't care less. vitamins and supplements

    ReplyDelete

  40. When you have had an encounter of taking your psychological, passionate and physical self to the dimension that lifting weights rivalry requires Acheter des noisettes

    ReplyDelete
  41. Recognition and affirmation of the Health Anxiety propensity, one stress rapidly following another in a recognizable circle that never closes. Consciousness of this cycle is dependably the initial step to compromise of the issue.crystal shop

    ReplyDelete
  42. Most likely to lots of online search engine for traveling, such as Google maps, RACQ, and the area of the city differs and also you do not get a clear or consistent area of where the CBD is. It does not exist past the council's town system. index

    ReplyDelete
  43. Health has dependably been a best issue among the general population everywhere throughout the world and they have been stressing over their health and the health of their friends and family for a very long time. go to this website

    ReplyDelete
  44. I literally eat here every week and the gnocchi with pink sauce is amazzzinggggg!! Definitely my favorite place to get pasta or pizza nearby and they're always super fast. get more info

    ReplyDelete
  45. The first is that social insurance change just influences uninsured individuals. buy bpc-157

    ReplyDelete
  46. The Paleo diet places a restriction on lots of food groups that have come to be a huge component of human society for hundreds of years. The most noteworthy limitations are dairy products, grains, and beans. Even though one could be able to dispute the healthfulness of these food groups, it doesn't alter the truth that human culture has actually depended on them for proceeded existence for centuries. navigate here

    ReplyDelete
  47. STIIIZY is a sleek, modern vaporizer that lets you access your medicine anytime, anywhere. Designed to fit easily in your pocket or handbag and to give off a subtle scent, medicating on the go has never been easier! A STIIIZY Pen Starter Kit combined with specialized pods produces an effective, health-conscious THC delivery system. STIIIZY is a brand you can trust no matter if you’re a veteran smoker or a new patient looking to break into the world of vaping. Stiiizy Skywalker OG Indica Pod Cartridge

    ReplyDelete
  48. This content is simply exciting and creative. I have been deciding on a institutional move and this has helped me with one aspect. click here to read

    ReplyDelete
  49. The information you have posted is very useful. The sites you have referred was good. Thanks for sharing this: buy pt 141

    ReplyDelete
  50. Nice to be visiting your blog once more, it has been months for me. Well this article that ive been waited for therefore long. i want this article to finish my assignment within the faculty.Pathology lab

    ReplyDelete
  51. We are really grateful for your blog post. You will find a lot of approaches after visiting your post. I was exactly searching for. Thanks for such post and please keep it up. Great work. mens health clinic

    ReplyDelete
  52. Building backlinks are one of the most important things if you want to get your website or blog ranking in Google search results. Backlinks are like a vote for your website. Fastest Growing service

    ReplyDelete
  53. Employers ought to be prepared to confront any inquiries posed by representatives with respect to the health advantage plan and clear their questions.ingredient distributors

    ReplyDelete
  54. Emotional health - imagine a little girl on a Christmas evening opening her presents, that for me is an example of good emotional health, because gratitude and happiness are the healthiest emotions for us.Natural Male Enhancement Supplement

    ReplyDelete
  55. Those with a degree in health promotion may also be qualified to be a personal health coach, work in a health and wellness center, or in a pregnancy facility or program.blog post

    ReplyDelete
  56. Societal values also influence how an individual feels about maintaining a certain level of health. To summarize, health means many things. It is a sense of complete well-being and the absence of disease.JUUL Pods Dubai

    ReplyDelete
  57. This blog is so nice to me. I will keep on coming here again and again. Visit my link as well.. banjo reviews

    ReplyDelete
  58. Healthy individuals are able to mobilise all their physical, mental, and spiritual resources to improve their chances of survival, to live happy and fulfilling lives, and to be of benefit to their dependants and society.cbd gummies

    ReplyDelete
  59. This is my first time i visit here. I found so many interesting stuff in your blog especially its discussion. From the tons of comments on your articles, I guess I am not the only one having all the enjoyment here keep up the good work oot care supply

    ReplyDelete
  60. Thus, the patient's psychological exhibition goes down and he encounters disposition changes. pure CBD products

    ReplyDelete
  61. Consistency is the most significant piece of taking CBD oil. It is acceptable to part the drops among morning and night, taking it generally simultaneously every day. CBD

    ReplyDelete
  62. Pretty good post. I just stumbled upon your blog and wanted to say that I have really enjoyed reading your blog posts. Any way I'll be subscribing to your feed and I hope you post again soon. Big thanks for the useful info. Augmentin

    ReplyDelete
  63. Testosterone levels have been decreasing over the last 20 years. Testosterone is the primary male sex hormone. It plays an important role in maintaining bone and muscle mass. Low levels of testosterone have been linked to lowered libido and diabetes.best site

    ReplyDelete
  64. In the health magazine, you can find stories of real people and how to cure from deadly diseases. You can find celebrities interviews and their practices for personal development. CBD

    ReplyDelete
  65. Wow, cool post. I'd like to write like this too - taking time and real hard work to make a great article... but I put things off too much and never seem to get started. Thanks though. Erections Pills Works

    ReplyDelete
  66. Family history tells more about your future health. Family history means you have more chances to end up suffering from a disease like your immediate family. For example, if your father has a history of heart problems or your grandmother has a high blood sugar level, you are likely to experience the same conditions sooner or later.https://www.headusnext.com/fitness-tips-useful-advice-to-make-you-fitter/

    ReplyDelete
  67. One needs to do some cardiovascular exercises so as to lessen or consume those additional fats. Presently the inquiry is what is a cardiovascular action? chiropodist bridgend

    ReplyDelete
  68. I found your this post while searching for some related information on blog search...Its a good post..keep posting and update the information. Elavil

    ReplyDelete
  69. I read a article under the same title some time ago, but this articles quality is much, much better. How you do this.. view more

    ReplyDelete
  70. Nice post! This is a very nice blog that I will definitively come back to more times this year! Thanks for informative post. click here

    ReplyDelete
  71. Thanks so much for this information. I have to let you know I concur on several of the points you make here and others may require some further review, but I can see your viewpoint. check it out

    ReplyDelete
  72. Very nice article, I enjoyed reading your post, very nice share, I want to twit this to my followers. Thanks!. la diete deux semaines

    ReplyDelete
  73. Pot influences memory, judgment and observation. Learning and focus aptitudes are debilitated among individuals who utilize the medication vigorously. Weed Seeda

    ReplyDelete
  74. Nowadays, CBD oil business is on the ascent. Truth be told, the market will appreciate fast development as there is a ton of interest for the item. https://cbdreamers.com/best-cbd-oils

    ReplyDelete
  75. It was wondering if I could use this write-up on my other website, I will link it back to your website though.Great Thanks. Dentist Mequon WI

    ReplyDelete
  76. This is very educational content and written well for a change. It's nice to see that some people still understand how to write a quality post.! A ‘What Dumbbell Weight Should I Use?’ Guide

    ReplyDelete
  77. Thank you so much for the post you do. I like your post and all you share with us is up to date and quite informative, i would like to bookmark the page so i can come here again to read you, as you have done a wonderful job. click here

    ReplyDelete
  78. The website is looking bit flashy and it catches the visitors eyes. Design is pretty simple and a good user friendly interface. where to buy codeine syrup

    ReplyDelete
  79. Spiritual health - is the most important aspect of health from my perspective because it influences all aspects of our health and often it is neglected. We have to take care of our soul as well as we take care of our physical body and the best way to do this is by meditation. 여성형유방증

    ReplyDelete
  80. You make so many great points here that I read your article a couple of times. Your views are in accordance with my own for the most part. This is great content for your readers. CBD Oil for Dogs

    ReplyDelete
  81. Hey what a brilliant post I have come across and believe me I have been searching out for this similar kind of post for past a week and hardly came across this. Thank you very much and will look for more postings from you. CBD as a Suitable Treatment for Binge Eating Disorder

    ReplyDelete
  82. Took me time to read all the comments, but I really enjoyed the article. It proved to be Very helpful to me and I am sure to all the commenters here! It’s always nice when you can not only be informed, but also entertained! Can CBD Oil Manage Symptoms Related to Blood Pressure

    ReplyDelete
  83. Very useful info. Hope to see more posts soon!. CBDfx Oil Tinctures

    ReplyDelete
  84. I was reading some of your content on this website and I conceive this internet site is really informative ! Keep on putting up. Royal CBD Full Spectrum Oil

    ReplyDelete
  85. This was an extremely wonderful post. Thanks for providing this info. Indiana Jones Jacket

    ReplyDelete
  86. I really appreciate the kind of topics you post here. Thanks for sharing us a great information that is actually helpful.
    rocketeer jacket

    ReplyDelete
  87. To oversee genuine populace health - that is, the health of a network - clinics and health frameworks must band together with a wide range of partners who share proprietorship for improving health in our networks. buy cbd products

    ReplyDelete
  88. I am happy to find this post Very useful for me, as it contains lot of information. I Always prefer to read The Quality and glad I found this thing in you post. Thanks Full Spectrum CBD Oil

    ReplyDelete
  89. It proved to be Very helpful to me and I am sure to all the commentators here! houston apetamin women vitamins

    ReplyDelete
  90. social and health benefits accomplished by offering these types of assistance at the work environment, hence giving the accessible information and proof fundamental for the nonstop improvement of work environment health the board. how to make cbd tincture

    ReplyDelete

Note: Only a member of this blog may post a comment.