COBRA Procedures Manual & E-Alerts

Agenda

• Background
  
• Purpose
  
• Administration
  
• Cost To Employers
  
• Penalties For Noncompliance With COBRA

• Employers And Plans Subject To COBRA
  
• Defining A Group Health Plan
  
• Maintaining A Group Health Plan

• The General COBRA Notice
  
• Consequences Of Failure To Provide The General COBRA Notice
  
• How To Send The General COBRA Notice
  
• HIPAA Notice

• Who Is A Covered Employee
  
• Who Is A Similarly-Situated Non-COBRA Beneficiary
  
• Who May Be A QB
  
• Who May Not Be A QB
  
• A QB’s Rights Under COBRA
  
• QBs Located Outside Of The Plan's Service Area
  
• Repeal Of The Core Coverage Requirement

• Defining A Qualified Event
  
• List Of Qualified Events
  
• What May Be A QE
  
• Expansion Of COBRA's Loss Of Coverage Definition
  
• What May Not Be QE
  
• Duration Of COBRA Coverage
  
• Expanded Coverage For Additional QEs (Multiple QEs)
  
• Special QE Issues: Gross Misconduct
  
• Special QE Issues: Disability
  
• Special QE Issues: Cessation Of Dependency Status
  
• Special QE Issues: Divorce Or Legal Separation
  
• Special QE Issues: Medicare And Initial QEs
  
• Special QE Issues: Medicare And Multiple QEs
  
• Determining The QE Date
  
• Providing More Than The Required COBRA Coverage
  
• COBRA Notice Rules: Reasonable Notice Procedures

• QE Notices
  
• What QE Notices Should Include
  
• To Whom Should QE Notices Be Sent
  
• When To Send A QE Notice
  
• How To Send A QE Notice
  
• Handling Coverage During The Election And Payment Period
  
• Responses To Provider Inquiries Concerning QBs

• Introduction
  
• Second Chance COBRA Election
  
• Health Coverage Tax Credit

• Coordination Of Administrative Resources
  
• Summary Plan Descriptions
  
• Keep The Envelopes, Use The Postmarks

• The COBRA Timeline
  
• Understanding And Managing The COBRA Timeline
  
• Employer And QB Notification To The Plan Administrator
  
• 14-Day Notification Period
  
• 60-Day Election Period
  
• 45-Day Retroactive Premium Payment Period
  
• 30-Day Grace Period
  
• Using The Correct Procedures
  
• Strategies For Protecting Against Accidental Free COBRA Coverage
  
• Finding Out About Other Coverage

• Determining COBRA Premiums For Insured Plans
  
• Determining COBRA Premiums For Self-Funded Plans
  
• Handling Rate Changes
  
• COBRA’s 12-Month Determination Period
  
• Determining Rates For Related QB’s Who Independently Elect COBRA
  
• Rates For A QB’s Newly Added Spouse or Dependent

• How To Bill Current QBs
  
• Who To Bill For COBRA Coverage
  
• Who Can Pay For COBRA Coverage
  
• What Is Timely Payment: Premium Payment Deadline
  
• What Is Timely Payment: Timely Payment
  
• What Is Timely Payment: Partial Payment
  
• What Is Timely Payment: Employer Subsidized / Alternative Coverage

• Who Is Entitled To Open Enrollment Rights
  
• Changes In Coverages During Open Enrollments
  
• Effect Of Plan Terms On QBs' Open Enrollment Rights
  
• Plan Changes And Their Effect On QBs
  
• Open Enrollment Changes By Active Employees And Potential QEs

• Introduction
  
• Protected Individuals
  
• Health Care
  Interaction With COBRA
  
• Election Notice
  
• Health Care Premiums
  
• USERRA Does Not Extend Beyond 18 Months Of Continuation Coverage

• Medicare Basics
  
• Entitlement vs. Eligibility
  
• Medicare And Initial QEs
  
• Medicare And Multiple QEs
  
• Medicare As An Event Terminating COBRA Coverage

• Defining Alternative Coverage
  
• Using Alternative Coverage To Offset COBRA
  
• Consecutive Coverage Method
  
• Concurrent Coverage Method
  
• Choice Method
  
• Making Your Alternative Coverage Method Work
  
• Choosing The Correct Method

• An Overview Of The Rules Governing Terminating COBRA Coverage
  
• Events Terminating COBRA Coverage
  
• Natural Expiration Of COBRA Continuation Period
  
• Termination Of COBRA Because Of Employer's Cessation Of Health Plan Sponsorship
  
• Termination Of COBRA For Failure To Pay Premiums
  
• Termination Of COBRA Because Of Other Group Health Plan Coverage Or Medicare Entitlement
  
• Termination Of Extended Disability COBRA Coverage Because Of Cessation Of Disabled Status
  
• Procedures For Terminating COBRA Coverage

• State Laws Health Care Continuation Rules
  
• COBRA And the Family And Medical Leave Act
  
• Conversion Coverage Rules
  
• Flexible Spending Accounts
  
• Deductibles, Limits, Split Family Units
  
• Penalties For Non-Compliance

• Documentation Form
  
• General COBRA Notice
  
• QE Notice - Termination/Reduction
  
• QE Notice - Cessation Of Dependency
  
• QE Notice - Death/Divorce - L.S./Medicare
  
• HIPAA Request For Certificate Of Coverage
  
• HIPAA Certificate Of Coverage
  
• HIPAA Certificate Of Coverage By Categories
  
• Termination Of COBRA Coverage Notice
  
• Responsibilities Checklist
  
• About The Manual
  
• IRS Notice 98-12
  
• About COBRA Continuation Coverage Rights
  
• Notice Of Unavailability Of Coverage

• Suggested Procedure For Sending The General COBRA Notice
  
• Suggested Procedure For Identifying QEs
  
• Suggested Procedure For Managing Cessation Of Dependency Status Issues
  
• Suggested Procedure For Sending QE Notices
  
• Suggested Procedure For Handling Coverage During The Election And Payment Period
  
• Suggested Procedure For Late and Partial Payments And Bounced Checks
  
• Suggested Procedure For Open Enrollment Changes
  
• Suggested Procedure For Determining Medicare Entitlement
  Suggested Alternative Coverage Procedure: Concurrent Coverage Method
  
• Suggested Alternative Coverage Procedure: Choice Method