Travis Software Official Blog

Most COBRA issues that result in litigation are settled prior to trial, and in those cases there is no public record of a judge’s rulings. A recent COBRA-related case actually went to trial and the ruling issued by a Federal District judge confirmed that the letters generated by Travis’ systems were “precise” and “unambiguous.” The case is Ratcliff v. Psychiatric Solutions, Inc., 2010WL 2814418 (W.D. La., July 16, 2010).

As part of our efforts to continue improving the WebCOBRA On Demand service, Travis has released several new enhancements during the last month, making it even more efficient, user-friendly, and beneficial to your COBRA administration needs.

Effective June 1, 2010, the ARRA language, ARRA posters, and “Request for Treatment as an Assistance Eligible Individual (AEI)” will not be included automatically in the default letters prepared by TravisCobra^TM and WebCOBRA for individuals with a qualifying event on or after June 1, 2010.

For the past several months, Travis’ developers have been working on significant improvements to WebCOBRA On Demand that are now either in the final stages of development or in our Quality Assurance/Testing process. The efforts have been delayed by the repeated changes to COBRA and ARRA over the past months which have required “all hands on deck” efforts by our staff to produce releases for you very quickly.

Even with all the ARRA releases, we have made progress on programming these major new improvements. They are now scheduled to be added to WebCOBRA over the next few months, and are close enough to delivery that we wanted to tell you about them.

Customer satisfaction is a top priority for Travis Software Corp., and Travis is working hard to make sure our customers know it. One way we are trying to improve customer satisfaction is to decrease the amount of time that a customer must wait to speak with a live support representative. Due to recent improvements, Travis support is currently providing the shortest hold time ever attained. The average hold time is typically less than one (1) minute.

On April 15, 2010, Congress passed and the President later signed the Continuing Extension Act of 2010 (the “Act”) that extended to May 31, 2010 the eligibility for the 65% premium subsidy for COBRA premiums for individuals that incur an involuntary termination of employment on or before that date. Prior to this Act, the eligibility time period for the COBRA premium subsidy expired on March 31, 2010. This Act modifies the American Recovery and Reinvestment Act of 2009 (ARRA), which was amended by the Temporary Extension Act of 2010 earlier this year.

Travis Software Corp. is working now on updates to both WebCOBRA On Demand and TravisCobra^TM to help you meet the requirements of this new law.

[Updated 4/26/2010] We plan to have the new release of TravisCobra^TM delivered to TravisCobra^TM Users on Tuesday, April 27, 2010. The new release of WebCOBRA On Demand will be implemented and available to WebCOBRA On Demand Users by Thursday, April 29, 2010 at 8:00 a.m. Additional testing was required for these updates to include the new ability to access and edit the ARRA Summary Letter and Request Form (as published by the DOL).

Travis Software Corp. is dedicated to providing customers with the most up-to-date COBRA Administration system. Recently, Travis reviewed New York state continuation laws and has updated the system to provide up to 36 months of continuation coverage regardless of qualifying event.

TravisCobra, WebCOBRA.com, TravisFlex and TBILL users can now use secure file transfer methods to send data to Travis and receive data from us. The new HITECH law requires that Protected Health Information (PHI) is transmitted using a secure methodology. Since the data sent to and from Travis in association with TravisCobra, TravisFlex and TBILL support issues contains PHI, and since WebCOBRA.com customers receive letters and data files containing PHI, we have now implemented “Secure FTP” (SFTP) servers to handle the sending and receiving of customer data .

Travis has seen its software adopted by a large number of new administrators during the past year, and the company has enjoyed record growth. We now work with over 700 COBRA administrators nationwide, with more than 100 of them working with Travis for the first time since ARRA was passed in February 2009!

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.