Travis Software Official Blog

In the past year, many submissions from the Travis Ideabook have made their way into our Travis Systems! Every year we add new features to our Travis products, and many of them come from you, our Travis Customers.

On March 2, 1010, the American Recovery and Reinvestment Act of 2009 (“ARRA”) was amended by the Temporary Extension Act of 2010 (H.R. 4691) (the “Act”) which, among other things, extends eligibility for the COBRA premium subsidy through March 31, 2010. The Act also includes a measure that extends premium assistance to eligible individuals that had or have a reduction of hours between September 1, 2008 and March 31, 2010 but did not elect COBRA coverage due to that qualifying event, and that later incur an involuntary termination of employment on or after March 2, 2010. Plan Administrators have new election period and notice responsibilities for such individuals.

From its founding in 1986 through 2009, Travis relied on outside attorneys on an as-needed basis for assistance with the design of new systems, with changes to existing software systems, and with verbiage of various correspondences. Over the course of last year, as changes were made to COBRA by the American Reinvestment and Recovery Act of 2009 (“ARRA”) and other rapid changes made to HIPAA, it became increasingly clear that Travis would benefit from having an attorney on staff to meet the increased pace of change regarding the administration of its systems.

Last week, Travis reported that the IRS released informal guidance regarding the proper procedure to claim credit for an ARRA premium subsidy on IRS Form 941. Through an email authored by a senior IRS Analyst, the IRS clarified that the ability to claim credit for the COBRA premium subsidy is based on the date that the COBRA premium payment is received, not the time period to which such credit is applied.

The following document will discuss how to import the ARRA Model Notice into the Letter Writer for Letters 79 – 81.

A senior tax analyst for the Internal Revenue Service (“IRS”) recently clarified how to properly claim the payroll tax credit on Form 941 for the ARRA premium subsidy. Through an informal announcement, the IRS agent stated that the ability to claim the credit for the premium subsidy is based on the year in which the payment is received rather than the year the payment is applied. The agent further stated that the date on which the employer is informed of a payment received is not at issue, but only when the payment was actually received.

On January 11, 2010, the U. S. Department of Labor (“DOL”) released an updated Fact Sheet and FAQs for Employees, which signals that the DOL is developing updated model notices to reflect the Department of Defense Appropriations Act, 2010 (“2010 DOD Act”).

Users of both TravisCobra and WebCOBRA.com are now able to use new releases of these systems reflecting the changes to the COBRA law enacted December 22nd as part of the Department of Defense Appropriation Act 2010.

All of us at Travis hope you’ve had a wonderful Holiday Season and are looking forward to a great New Year. As we do each year at this time, we want to give you the days in 2010 when Travis offices will be closed for holidays.

President Obama signed an extension and expansion of the COBRA premium subsidy into law on December 19th, giving existing COBRA qualified beneficiaries who had qualified as Assistance Eligible Individuals (AEIs) an opportunity to receive as many as six months of additional premium subsidy, and providing new QBs with up to 15 months of the 65% subsidy.

Now that the Department of Defense Appropriation Act, 2010 DODAA, 2010, or H.R. 3326)has passed the Senate, Congress has given a Christmas gift to several hundred thousand existing COBRA qualifying beneficiaries and to others who lose their coverage during the first two months of 2010. An extension of the 65% ARRA subsidy of COBRA premiums from nine to fifteen months, and possible eligibility for the subsidy to those who have COBRA qualifying events of termination through February 28, 2010.

With the latest application update to WebCOBRA.com, users can now generate a letter that will inform a QB that they have applied for TAA and will give them further information about HCTC.

While Congress is considering extending the COBRA Premium subsidy provided by ARRA there remains the possibility that January 1, 2010 will come and go without ARRA being extended. If no extension is enacted, those who have qualifying events in 2010 will not be eligible to become Assistance Eligible Individuals (AEIs) under ARRA, as ARRA only provides for subsidy for those who have qualifying events between September 1, 2008 and December 31, 2009.

States are continuing to enact legislation affecting State Continuation and Mini Cobra and to support our customers, we updated our software in preparation. The following States have changed their coverage options, and we have modified WebCOBRA.com and TravisCobra to reflect these changes:

States are continuing to enact legislation affecting State Continuation and Mini Cobra and to support our customers we updated our software in preparation. The following States have changed their coverage options:

Illinois

Illinois mini cobra has been extended to 12 months of continuous coverage from the FDLOC for events such as Termination and Reduced hours.

Oregon

Oregon mini cobra and State Continuation enhancements have been implemented for events occurring between 09/01/2008 – 12/31/2009. Mini Cobra for Oregon will now offer 9 months of coverage from the FDLOC for the following events:

• Termination- 31 day election period

• dependents loss of coverage due to employees death – 60 day election window, 45 day payment grace

• divorce – 60 day election window, 45 day payment grace

Ohio

Ohio Mini Cobra have also decided to offer a 12 month coverage period from the FDLOC for the following event that occurred between 04/01/2009 – 12/31/2009.

• Termination- 31 day election period

Virginia

Virginia State QB’s enrolled in State Mini cobra are now eligible to receive a total of 9 months coverage period from the FDLOC for events occurring between 09/01/2008 – 12/31/2009.

• Termination- 60 day election period

To inquire about any of these State mandated changes please refer to each State’s Insurance website or find out who to contact at this site.