COBRA Training & Certification Program

Overview

• Issues with COBRA – Cost Issues And the Affordable Care Act
• What Is COBRA?
• Historical Costs
• Inception
• Updates
• Responsibility
• Plan Obligations
• Excise Tax Penalties
• Contractual Obligations
• Fiduciary Responsibilities
• Penalties For Noncompliance With COBRA
• Issues with COBRA – Cost Issues And the Affordable Care Act
• Coordinating COBRA And The Employer Mandate

Employers And Plans Subject To COBRA

• Basic Rules For Determining Whether A Plan Or Employer Is Subject To COBRA
• Defining A Group Health Plan
• Exceptions
• Other Exceptions
• Determining Eligibility Or Exemption: Employees Not Counted
• Determining Eligibility Or Exemption: Counting Part-Time Employees
• Determining Eligibility Or Exemption: Typical Business Days
• Determining Eligibility Or Exemption: Multi-Employer Health Plans
• Determining Eligibility Or Exemption: Foreign Members of Employers’ Controlled Groups
• Determining Eligibility Or Exemption: Compliance Suggestions

Individuals Covered By COBRA

• Individuals Eligible For COBRA
• A QB’s Rights
• A QB’s Rights: Notification
• A QB’s Rights: Election
• Other QB "Rights"
• Who May Not Be A QB, And Who Does Not Have QB Rights
• Qualified Beneficiaries Located Outside of Plan’s Service Area

The General (Initial) COBRA Notice

• The General COBRA Notice
• The General COBRA Notice Overview: Rights and Responsibilities
• The General COBRA Notice: Responsibilities of Employees & Qualified Beneficiaries
• The General COBRA Notice: Employee's Notification Procedures
• The General COBRA Notice: Content of Employee Notifications
• The General COBRA Notice: Common Administrative Errors
• Consequences Of Failure To Provide The General COBRA Notice
• Suggested Procedure For Sending General COBRA Notice

Qualifying Events

• About Qualifying Events
• What May Be A QE
• What May Not Be A QE
• Duration Of COBRA Coverage
• Expanded Coverage For Additional QE’s
• COBRA Notice Rules: Reasonable Notice Procedures
• QE Issues: Gross Misconduct
• QE Issues: Disability
• QE Issues: Disability
• QE Issues: Cessation Of Dependency Status
• QE Issues: Cessation Of Dependency Status
• Suggested Procedures For Managing Cessation Of Dependency Status Issues
• QE Issues: Divorce Or Legal Separation
• QE Issues: Divorce Or Legal Separation Notification Requirements
• Suggested Procedure For Identifying Divorce Or Legal Separation QEs

Qualifying Event Notices

• Notice Requirements For Employers
• What QE Notices Should Include
• To Whom Should QE Notices Be Sent
• When To Send A QE Notice
• Suggested Procedure For Sending QE Notices
• Model Updated Alternative Notice

The COBRA Timeline

• Defining The COBRA Timeline
• Understanding & Managing The COBRA Timeline
• Managing The COBRA Timeline
• The 14-Day Notification Period
• The 60-Day Election Period
• Administrative Tip For The 60-Day Period
• The 45-Day Retroactive Premium Payment Period
• The 30 Day Grace Period

Calculating COBRA Premiums

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

Billing & Collection Options

• Who To Bill For COBRA Coverage
• Who Can Pay For COBRA Coverage
• Internal Billing & Collection Options
• External Billing & Collection Options

COBRA's Premium Payment Issues

• Defining Timely Payment
• Determining If Timely Payment Was Made
• Partial Payments & Bounced Checks
• Suggested Procedure For Late And Partial Payments & Bounced Checks
• Charging For Employer-Subsidized Or Alternative Coverages

Events Terminating COBRA Coverage

• 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
• Notice of Unavailability of COBRA Coverage
• Procedures For Terminating COBRA Coverage

Other Rules & Requirementes

• Conversion Issues On Termination Of COBRA Coverage
• Region-Specific HMO Issues
• Stop-Loss Carrier And Insurance Company Issues With Terminating COBRA Coverage
• Coordination Of Administrative Resources
• State COBRA Rules
• Conversion Coverage Rules
• Expansion Of COBRA’s Loss of Coverage Definition
• Deductibles, Limits, Split Family Units

Employer Safeguards

• Summary Plan Descriptions
• Employer And QB Notification To The Plan Administrator
• Determining The Start Of The Election Period
• Issues To Consider For Determining The Start Of The Election Period
• Responses To Provider Inquiries Concerning Qualified Beneficiaries
• Handling Coverage During The 60 Day Election Period
• Suggested Procedure For Handling Coverage During the Election & Payment Periods
• Providing More Than The Required COBRA Coverage
• Aggressively Identify QEs
• Exit Interview Notices And Delivery Systems
• Keep The Envelopes, Use The Postmarks
• Affirmative Rejections / Waivers
• Implement "Use Equals Election" Rules

Medicare

• Medicare Basics
• Medicare: Entitlement vs. Eligibility
• Suggested Procedure For Determining Medicare Entitlement
• Medicare As An Initial QE
• Medicare As A Multiple QE

Open Enrollment

• Open Enrollment Rights
• Plan Changes And Their Effect On QBs
• Open Enrollment Changes By Active Employees Suggesting Possible QEs

Mergers & Acquisitions

• Mergers, Acquisitions, And Plan Terminations

COBRA And The Family And Medical Leave Act

• COBRA & The Family And Medical Leave Act

Alternative Coverage Rules

• Defining Alternative Coverage
• Alternative Coverage: Consecutive Coverage Method
• Alternative Coverage: Concurrent Coverage Method
• Alternative Coverage: Choice Method
• Selecting An Alternative Coverage Method
• Implementing The Selected Alternative Coverage Method

USERRA

• Introduction
• Protected Individuals
• Exceptions To The Five-Year Limit
• Employee Notice Of Service
• Nondiscrimination
• Reemployment Rights
• Time Limits For Reporting Back To Work
• Re-Employment Not Required
• Failure To Timely Report
• Required Documentation
• Job Reinstatement Criteria
• Disability Related To Service
• Undue Hardship
• Employee Discharge
• USERRA And FMLA
• Health Care
• Interaction With COBRA
• Election Notice
• Health Care Premiums
• USERRA Extends Beyond 18 Months Of Continuation Coverage