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August 9, 2010
Our office will be closing early on Thursday August 26th 2010 for a Company sponsored event.
eCOBRA will shut down for the day at 1:00 pm CDT. eCOBRA will resume work the following day at
8:00 am CDT. We are sorry for any inconvenience this may cause you.
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July 26, 2010
The American Recovery and Reinvestment Act (ARRA) provides a COBRA premium reduction for
eligible individuals who are involuntarily terminated from employment through the end of May 2010.
Due to the statutory sunset, the COBRA premium reduction under ARRA is not available for
individuals who experience involuntary terminations after May 31, 2010. However, individuals who
qualified on or before May 31, 2010 may continue to pay reduced premiums for up to 15 months, as
long as they are not eligible for another group health plan or Medicare.
The Unemployment Compensation Extension Act of 2010 signed by the President on July 22, 2010,
did not extend the COBRA premium reduction.
Read more at: http://www.dol.gov/ebsa/cobra.html
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July 13, 2010
Until further notice, individuals who are involuntary laid off or terminated on or
after June 1 are not eligible to receive the 65 percent COBRA premium subsidy (known as
ARRA). Assistance eligible individuals already receiving the premium subsidy, and are
eligible to continue to receive it are not affected (up to a period of 15 months).
eCOBRA will no longer generate ARRA related documents for any qualifying events which
occur on or after June 1, 2010 because the subsidy language is no longer applicable.
Congress and the Senate continue to debate the expired ARRA program as well as an
unemployment benefits extension. eCOBRA will keep you alerted of any changes as they occur.
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June 14, 2010 Status of the Premium Subsidy under ARRA
The COBRA Premium subsidy eligibility period under ARRA expired on May,
31 2010. These means certain qualifying events occurring on or after
June 1, 2010 will no longer qualify for premium reduction. Congress has
extended the subsidies four times since February 2009 but the latest
effort stalled before Memorial Day recess. This week Congress will
consider another extension however funding of the bill is up for debate.
An amendment to the jobs bill would extend the COBRA premium assistance
through November 30, 2010.
eCOBRA is closely monitoring congressional activities regarding a
possible ARRA extension (likely to include a retroactive component) and
will update our systems quickly if another extension is enacted. If you
have any questions regarding ARRA or our administrative services, please
contact our support team at ecobra.com.
For more information regarding COBRA Continuation Coverage Assistance Under ARRA, visit
https://www.dol.gov/ebsa/COBRA.html.
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June 11, 2010 Survey Request
eCOBRA wants your feedback. Please let us know how we are doing by
taking this short online survey.
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May 28, 2010
This afternoon the tax extender legislation passed the House, and the
Senate is expected to vote on it the week of June 7th. However, in an
effort to limit its costs, a number of changes were made at the last
minute. The COBRA subsidy extension was stripped from the bill. The
House may try to do a separate extension when it returns after the
Memorial Day recess. However, right now, the COBRA subsidy will expire
on May 31, 2010 and will not cover new involuntary terminations after
May 31, 2010.
By Mark Stember, JD Kilpatrick Stockton (From the KS Health and Welfare Team)
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May 21, 2010 May 2010 Compliance Announcement
Read the PDF announcement from eflexgroup.
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May 21, 2010 H.R. 4213: American Workers, State, and Business Relief Act of 2010.
Next week, H.R 4213 goes to a conference committee of senators and
representatives to work out differences in the versions of the bill. If
the differences are worked out, the bill will go to the President before
becoming law. This bill or a version of the bill should pass within the
next week. The bill could extend the eligibility of ARRA through
December 31, 2010. We'll keep you informed of legislative alerts as
they occur.
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May 17, 2010 COBRA Subsidy: Will it Expire or be Extended (Again)?
The COBRA premium subsidy eligibility period under the American Recovery
and Reinvestment Act (ARRA) is set to expire on June 1, 2010 (unless
further legislation is passed). Currently the premium reduction is
available to certain individuals who experience a qualifying event
relating to COBRA continuation coverage that is either 1) an involuntary
termination of employment during the period of September 1, 2008 through
May 31, 2010; or 2) a qualifying event that is a reduction of hours
occurring at any point from September 1, 2008 through May 31, 2010
followed by a termination of employment on or after March 2, 2010 and by
May 31, 2010.
While the economy is showing strong signs of progress, eCOBRA believes
another ARRA extension is likely. H.R.4213-American Workers, State, and
Business Relief Act of 2010-was passed by the House in early December
2009 and passed by the Senate in early March 2010. The bill extends the
filing deadline for existing tiers of unemployment benefits until
December 31, 2010. COBRA health care subsidies (ARRA) for the unemployed
would also be extended. The total cost of the bill is estimated at $140
billion, with $80 billion of that allocated to extended unemployment
benefits. None of the cost is offset with new revenues. If funding isn't
approved for H.R.4213, employers will continue to see additional
incremental ARRA extensions. Past incremental ARRA extensions include
the Department of Defense Appropriations Act 2010, Temporary Extension
Act 2010 and the Continuing Extension Act of 2010.
For more information regarding COBRA Continuation Coverage Assistance Under ARRA, visit
https://www.dol.gov/ebsa/COBRA.html
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April 28, 2010
New model COBRA notices reflecting the latest extension of the premium subsidy law (Continuing Extension Act of 2010) have been
posted to the website of the U.S. Department of Labor (DOL).
eCOBRA is working quickly to have all updates and re-notifications processed by the end of this week (April 30, 2010).
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April 28, 2010 Just so you know - the latest changes to American Reinvestment and Recovery Act (ARRA)
HR 4851 extended the COBRA subsidy period end date from March 31, 2010 to May 31, 2010. This bill extends the eligibility period by two months.
We'll perform a system upgrade by the end of this week and keep your plan in compliance by updating participant letters,
as required by Federal regulations. During the week of April 26, 2010 - April 30, 2010 we will re-notify all participants
who incurred a qualifying event on or after April 01, 2010.
We would like to take this opportunity to thank you for your business and support, during these ARRA regulation changes. Please know that we appreciate your choosing to work with eCOBRA and we are working hard to make these changes as smooth as possible while keeping you in compliance.
If you have any questions, please contact:
If you have any comments or suggestions regarding eCOBRA services, please let us know at www.ecobra.com.
We also specialize in services like: Flexible Spending Accounts (FSAs), Health Reimbursement Arrangements (HRAs),
Health Savings Accounts (HSAs) and transportation plans. Features like customizable debit cards, private labeled Websites,
personal account administrators, and proven service metrics make eflexgroup & eCOBRA industry leaders. Visit eflexgroup.com
for more information or contact efgsales@eflexgroup.com.
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April 23, 2010
The DOL's webpage on health care reform now contains a page of
frequently asked questions about health care reform and COBRA. In
short, the health care reform legislation did not make any direct
changes to COBRA other than the recent extension of the premium subsidy
eligibility period under ARRA (American Recovery and Reinvestment Act).
http://www.dol.gov/ebsa/faqs/faq-PPACA.html
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April 16, 2010
Yesterday the Senate passed HR 4851, the Continuing Extension Act of
2010, which included an extension of the COBRA subsidy. Later, the
House approved the bill as well, and President Obama signed the measure
late last night.
The bill extends the end of the COBRA subsidy period from March 31, 2010
to May 31, 2010.
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April 12, 2010
COBRA Extension under ARRA? The Senate is expected to amend H.R. 4851 to make COBRA benefits and Unemployment Insurance retroactive
and extend them through the end of May 2010. Another bill (HR 4213) being considered by Congress would extend the COBRA subsidy through
the end of this year. This bill has already passed the Senate and is now before the House, where a vote has not been scheduled. eCOBRA
will keep our clients and COBRA participants informed of legislative changes once signed into law.
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March 12, 2010
Congress has made changes to the COBRA subsidy program with the passage of the Temporary Extension Act of 2010. Key highlights of the Act include:
- February 28, 2010 eligibility deadline for the COBRA subsidy extended until March 31, 2010.
- Extended COBRA subsidy program to individuals who lost their health coverage as a result of a reduction of their hours of employment and who are later involuntarily terminated on or after March 2, 2010.
- A new second election right is provided to individuals that did not elect COBRA coverage following a reduction of hours but are now eligible for the COBRA subsidy.
Under prior law, the COBRA subsidy was available only to individuals who lost health coverage as a result of an involuntary termination of employment. The Act now adds a new (but limited) category of assistance eligible individuals. Under this new category, an individual (and his or her covered family members) may be eligible for the subsidy if the individual:
- Loses health coverage due to a reduction of hours of employment during the COBRA subsidy eligibility period (currently, September 1, 2008 to March 31, 2010); and
- After the reduction of hours, is involuntarily terminated from that employment on or after March 2, 2010, and on or before the last date of the COBRA subsidy eligibility period (currently, March 31, 2010).
Here at eCOBRA, we have already received a software update which accommodates all recent changes in the law.
- Modifies the standard COBRA Election Notice to include individuals that are now eligible for premium assistant pursuant to the Act.
- The COBRA Notice and General Notice have been updated to reflect the new premium eligibility dates.
- Provides the ability to re-notify individuals whose qualifying event dates were previously not eligible for assistance but now are. Ability to re-notify individuals whose COBRA election notices were accepted prior to the date of the new software release letting appropriate participants know they may be eligible for premium assistance.
On or after March 15, 2010 eCOBRA will have a supplemental software update that provides the ability to:
- Include a new qualifying event code for "Reduction of Hours Followed by an Involuntary Termination of Employment" that can be used for those who incurred a qualifying event of a reduction in hours between 9/1/2008 and 3/31/2010, and were offered COBRA but who either did not make (or made and discontinued) an election of COBRA, and who later incur an involuntary termination of employment between 3/2/2010 and 3/31/2010.
There is a new Activation Form on our secure employer portal called "QB Look Back for Reduction in Hours Form" for employers to complete if there are any circumstances relating to the new category of reduction of hours followed by an involuntary termination.
PEO or multi-employers may have a difficult time examining all reduction in hours events on and after 9/1/2008, in light of this new qualifying event type. More plainly, employers must ask themselves "Was this involuntary termination (on or after 03/02/2010) preceded by a reduction in hours that occurred on or after 9/1/2008?"
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March 5, 2010 ARRA Amended on March 2, 2010
The American Recovery and Reinvestment Act of 2009 (ARRA), as amended on
March 2, 2010 by the Temporary Extension Act of 2010, provides for
premium reductions for health benefits under the Consolidated Omnibus
Budget Reconciliation Act of 1985, commonly called COBRA. Eligible
individuals pay only 35 percent of their COBRA premiums and the
remaining 65 percent is reimbursed to the coverage provider through a
tax credit. To qualify, individuals must experience a COBRA qualifying
event that is the involuntary termination of a covered employee's
employment. The involuntary termination must generally occur during the
period that began September 1, 2008 and ends on March 31, 2010. (An
involuntary termination of employment that occurs on or after March 2,
2010 but by March 31, 2010 and follows a qualifying event that was a
reduction of hours that occurred at any time from September 1, 2008
through March 31, 2010 is also a qualifying event for purposes of ARRA.)
The premium reduction applies to periods of health coverage that began
on or after February 17, 2009 and lasts for up to 15 months. See
Temporary Extension Act of 2010.
We are examining the rules and will take necessary steps to ensure you
are in full compliance with the new bill. We will send full details
regarding ARRA eligibility, notice requirements and administrative
action steps very soon. Please note that Congress is considering a
further extension and expansion of the ARRA COBRA subsidy, possibly
extending eligibility for the 15-month subsidy to those incurring an
involuntary termination of employment through December 31, 2010.
To see the Temporary Extension Act of 2010,
go to https://www.dol.gov/ebsa/COBRA.html.
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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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April 16, 2009 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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