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Breaking News! |
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February 9, 2010
Another ARRA extension? The Senate will review another ARRA extension
as proposed in the "Hiring Incentives to Restore Employment Act"
otherwise known as the Jobs Bill. At this time, the Bill is only a
draft however another extension is expected shortly. We will keep our
clients informed of legislative changes.
The proposal calls for a three-month extension of the eligibility period
for the COBRA premium subsidy from 2/28/10 to 5/31/10. In addition, it
calls for clarifications to ARRA provisions related to COBRA
continuation resulting from reductions in hours. The relevant section
is 611, which begins on page 99.
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January 27, 2010
eCOBRA has posted sample documents of our ARRA extension mailing as
required under the Department of Defense Appropriations Act, 2010 (2010
DOD Act). Sample documents are located under the client toolbox after
member log on. Our mass letter mailing was performed on January 20,
2010. As required we notified active, pending, and certain terminated
participants of new rights under the 2010 DOD Act.
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January 13, 2010
United States Department of Labor releases updated COBRA documents following the Department of Defense Appropriation Act, 2010 (2010 DOD Act). http://www.dol.gov/ebsa/COBRAmodelnotice.html
Other informative links:
The update fact sheet is available at:
http://www.dol.gov/ebsa/newsroom/fsCOBRApremiumreduction.html
The FAQs for employees are available at:
http://www.dol.gov/ebsa/faqs/faq-cobra-premiumreductionEE.html
The job loss poster is available at:
http://www.dol.gov/ebsa/pdf/joblossposter2.pdf
The flyer for employees is available at:
http://www.dol.gov/ebsa/pdf/cobrastimulusflyer2.pdf
The flyer for employers is available at:
http://www.dol.gov/ebsa/pdf/cobrastimulusflyer1.pdf
The flyer for employees on the application for review is available at:
http://www.dol.gov/ebsa/pdf/distributionflyer09.pdf
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December 21st, 2009
COBRA Subsidy Extension Approved!
The new provisions are contained in the Department of Defense Appropriations Act. Section 1010. Page 64.
- This Act will extend the length of the ARRA subsidy period from the current nine months to fifteen months.
- Eligibility for the ARRA subsidy would be available to qualifying event dates through February 28, 2010.
- Assistance Eligible Individuals (AEIs) whose subsidy period expired on November 30, 2009 will be able to make a retroactive premium payment.
Further details regarding this Act will be sent to eCOBRA clients directly.
eCOBRA participants will be notified of additional rights shortly. Our goal
is to meet the new compliance changes as quickly as possible while
maintaining service levels.
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December 16th, 2009
It's coming down to the wire for the COBRA subsidy, but it now appears
likely that the COBRA subsidy will be extended as part of the Department
of Defense Appropriations Act. Both the House and the Senate need to
approve this bill prior to the Holiday recess. If the extension remains
in the final bill, the key provisions of the extension are as follows:
Extension of COBRA Subsidies. If enacted, individuals experiencing a
qualifying event as a result of an involuntarily termination from
employment on or before February 28, 2010 would be eligible for
subsidized coverage. This eligibility period would have expired on
December 31, 2009 under ARRA. The amendment clarifies that eligibility
of the subsidy is based on incurring the qualifying event within this
time period. The individual may elect COBRA coverage at a later point
(for example, if the employer provides subsidized coverage that delays
the COBRA start date). However, this appears to also present a problem,
because an employer can extend the qualifying event date by extending
active coverage post-termination. Thus, the IRS and DOL would need to
clarify that point.
Maximum Coverage Period. The maximum period of subsidized coverage
would be 15 months rather than the 9 months provided under ARRA.
More Notifications. Group health plans would be required to provide a
notification of the subsidy extension within 60 days of enactment to all
individuals eligible for the subsidy after October 31, 2009, and to
individuals who become eligible for the subsidy after the bill is
enacted. (The notice to future eligible individuals could be
incorporated into the existing ARRA notice.)
Retroactive Payments. Individuals who lost their coverage as a result
of not timely paying the December (or later) premiums would be entitled
to elect coverage retroactively by paying the premium within 60 days of
enactment or, if later, within 30 days of receiving notification of the
extension from the group health plan. If someone remained on COBRA by
paying the full rate in December (and later months), they would be
entitled to a refund under the existing refund ARRA rules.
Click here to view a list of the current provisions.
Mark L. Stember
Kilpatrick Stockton LLP
Suite 900
607 14th Street, NW
Washington, DC 20005
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December 2nd, 2009
Questions regarding current eligibility for the COBRA premium reduction
http://www.dol.gov/ebsa/faq-cobra-arra.html
Q1: If an employee is involuntarily terminated no later than December
31, 2009, but the qualified beneficiary is not eligible for COBRA until
on or after January 1, 2010, is the qualified beneficiary eligible for
ARRA premium assistance?
No. Under ARRA, an assistance eligible individual is a qualified
beneficiary as the result of an involuntary termination that occurred
during the period from September 1, 2008, through December 31, 2009, is
eligible for COBRA continuation coverage at any time during that period,
and elects the COBRA continuation coverage. An individual who does not
become eligible for COBRA until after December 31, 2009 does not meet
the qualifications to be an Assistance Eligible Individual and would
therefore be ineligible for the ARRA premium assistance. Please note
that this is the correct information based on the current law; however,
there is pending legislation that could extend the ARRA premium
assistance.
Q2: My plan has told me that ARRA expires or stops on December 31, 2009.
If I am an assistance eligible individual who was involuntarily
terminated no later than December 31, 2009 and became eligible for COBRA
no later than December 31, 2009, can I still receive the full 9 months
of ARRA premium assistance?
Yes. Assistance eligible individuals are entitled to receive the full 9
months of premium assistance as long as they remain eligible. For
example, if an assistance eligible individual started COBRA on November
1, 2009, they would be entitled to 9 months of ARRA premium assistance
from November 1, 2009 through July 31, 2010 as long as they remained
eligible. Please note that this is the correct information based on the
current law; however, there is pending legislation that could extend the
ARRA premium assistance. Please subscribe to the COBRA page for updates.
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December 1st, 2009
The Consumer Driven Health Care Institute contacted us at eCOBRA to participate in a University of Minnesota a research proposal to evaluate the affect of the 65% COBRA subsidy enacted by Congress this year. The proposed research will be conducted using current pre- and post-COBRA subsidy data from the largest administrators of COBRA benefits for employers that are self-funded under ERISA and health insurers. If you are a self-funded employer under ERISA and are interested in participating in this study, please contact cobra@eflexgroup.com or call 608-268-5133 by December 18, 2009 for more information. Please note: we are only interested in self-funded employers.
The results of this study will provide valuable information about COBRA use and provide policymakers with critical program information.
Thank you for selecting eCOBRA as your third party COBRA Administrator. We look forward to working for you in 2010.
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November 11, 2009
Congress Introduces ARRA Extension Legislation
Representative Joe Sestak (D-PA), a member of the House of Representatives Education and Labor committee, introduced the Extended COBRA Continuation Protection Act (H.R. 3930) on October 26, 2009. The proposed bill would amend the American Recovery and Reinvestment Act of 2009 (ARRA) to extend the eligibility period and maximum period for COBRA premium assistance. Currently, eligibility for the nine-month subsidy is limited to individuals who have been involuntarily terminated from employment on or after September 1, 2008, through December 31, 2009 and who lose coverage during that period.
According to Sestak, the new subsidy would extend the total allowable time individuals could receive the COBRA subsidy by six months (from nine to 15 months); the subsidy to individuals who are involuntarily terminated between January 1, 2010, and June 30, 2010; and eligibility for traditional COBRA coverage an additional six months (from 18 to 24 months) for individuals who were terminated at the beginning of the recession in 2008.
Under the proposed legislation, individuals who were enrolled in the original COBRA subsidy since February would continue until at least May 2010.
The bill has not yet passed, however, Jon Meyer eCOBRA's Director of COBRA and Human Resources states, "Our goal in the COBRA department is to make sure our staff and clients always know what is happening with the ever changing COBRA world. eCOBRA's focus is 100% compliance in all aspects of legislation. When changes come we are ready, and most importantly, our clients are protected."
eCOBRA is a division of eflexgroup and national Third Party Administrator (TPA) of COBRA, pre-tax employee benefits, HRAs, HSAs, and Cafeteria Plans. Founded on the idea that administration of benefit t plans should be easy, eflexgroup/eCOBRA is a different kind of TPA. With a customer focus and Lean Six Sigma quality tools, we are creating the highest standards of customer service in the TPA market. Our COBRA expertise and compliance provide the ultimate peace of mind.
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September 25, 2009
We've got great news! At eCOBRA, we now offer you Daily Reports, which provide you with virtually real-time data anytime you need it.
The available Daily Reports include:
- Active Report
- Termination Report
- Notification Report
Note: The Payment Report is not available as a Daily Report. You may run the Active Report to determine participants paid to date. We don't recommend using the new Daily Reports for monthly benefit reconciliation as the data could change daily. You should continue using the available Monthly Reports for benefit reconciliation.
Log In above and click on the Reports tab to see the new Daily Reports.
Also, to better meet the needs of our clients, we have upgraded and reconfigured our web servers. www.ecobradmin.com has been replaced by www.ecobra.com. The main improvement you will notice is the speed of the site, followed closely by the ability to log in to your account on the front page.
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July 9, 2009
941 Subsidy Report is now available under the Reports menu. This report will assist you when filing the 941 tax form. Additional information is available after logging on when running the report.
Helpful links regarding general 941 questions:
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June 4, 2009
IRS Posts Q&As on COBRA Premium Subsidy Issues. The IRS added Q&As to the following categories:
- Administration and eligibility
- Form preparation
- Reporting and documentation
No Q&As were added to the taxability and recapture section.
More information can be found by clicking here.
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May 21, 2009
New Application for Review of Premium Reduction Denials Introduced by the Department of Labor (DoL)
As you're aware, ARRA allows qualified beneficiaries to request a review of their termination status. Until now, there was no formal process for such reviews. Please click here for more details.
As always, you may visit www.ecobra.com for continued developments pertaining to ARRA.
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ARRA Status (as of 04/16/2009)
Status:
- ARRA re-notification packets were mailed out last week beginning 04/06/09. We will continue to process ARRA re-notification packets as data is received.
- Next month (05/10/09) we will post an additional “ARRA Notification Report” per the mass mailing on 04/06/09.
- Next month (05/10/09) we will include an additional column to our existing Active Report. The additional column will inform you whether someone has been verified as an AEI (Assistance Eligible Individual) under premium reduction.
- We are continuing to work on the stimulus reduction reporting on behalf of our clients. By second quarter, we hope to have an online “Stimulus Premium Report” available to assist you with 941 Tax Reporting. Until this report is made available online, you may request Stimulus Premium Reports manually by emailing our office at cobra@eflexgroup.com. Please note participants are in the beginning stages of ARRA verification. Due to volume, we ask you only initiate this request if you are filing the 941 Form weekly or monthly. We will provide additional online tools as soon as they are available to assist you with Premium Reporting process.
Please visit this page for further updates. Using our Web service will help minimize
telephone calls and allow our eCOBRA team to focus on completing the mailings.
DOL Releases COBRA Model Notices |
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