The following notice was sent to client employer groups and their insurance agents/brokers of record today, February 23, 2009.
The American Recovery and Reinvestment Act of 2009 (a.k.a. The Economic Stimulus Bill), hereafter referred to as “ARRA,” makes substantial, but temporary, changes to the rules governing the continuation of health coverage under COBRA along with a number of other modifications affecting welfare benefit plans.
Benefit Allocation Systems, Inc, (BAS) and Cobra Control Services, LLC (CCS) are preparing to provide you with the tools to necessary for your compliance with ARRA as it pertains to the changes under COBRA. As part of our COBRA services for the fees outlined below, BAS and CCS will provide the necessary notification, billing, remittance, and reporting services that are required under the new law.
The attached document summarizes ARRA requirements with respect to COBRA administration and the services BAS/CCS will provide your group.
Your Responsibilities
While evaluating our clients’ COBRA data with respect to ARRA, we have discovered many instances where administrators or their designees did not discern between involuntary and voluntary separation from service when assigning an employee’s qualifying event.
We believe this may have occurred because, prior to ARRA, choosing either the voluntary or involuntary qualifying event did not affect the offer or duration of COBRA coverage. Since the key determinant of a qualified beneficiary’s eligibility to be an Assistance Eligible Individual is the assigned qualifying event, it is important that the employer or its designee review each employee terminated on or after September 1, 2008 (and before December 31, 2009), and modify the assigned qualifying event, as necessary.
BAS/CCS is providing you with a new online program that lists each employee who was/is eligible for COBRA coverage on or after September 31, 2008 (and before December 31, 2009) to enable you to modify any assigned qualifying event, so you can accurately identify involuntary versus voluntarily separated employees, and we can use these designations to mail the appropriate notices to each set of former employees and their qualified beneficiaries.
To access the Qualifying Event Verification program online, log on to your administrative account from www.CobraControl.com or www.MyEnroll.com and under the COBRA menu select “Qual. Event Verification.”
If you have any questions about this information, please contact us.
Sincerely,
Benefit Allocation Systems, Inc.
Cobra Control Services, LLC
(888) 887-6187
Info@CobraControl.com
The information contained herein is for informational purposes only and is not intended as legal advice, nor is it intended to advise you of your obligations under ERISA, COBRA, HIPAA or the American Recovery and Reinvestment Act of 2009.
Filed under: Administration, American Recovery and Reinvestment Act of 2009, COBRA
