Travis Software Official Blog

Ironic, isn’t it, that the ARRA changes to COBRA, which represent the most significant amendments to the COBRA law since its original enactment in 1986, are temporary. At least they may be temporary.

Travis Software’s system developers continue to work to further refine the ARRA modifications we first put in place for TravisCobra and WebCOBRA.com last February. Improvements such as changing the ARRA Premium Reduction report, making it easier for you to change a QB’s AEI status and further standardizing disbursement reporting are all scheduled to be released soon for both TravisCobra and WebCOBRA.com.

At the same time, we are already working on system changes that are designed to help you administer COBRA if and when ARRA expires for each QB. Some of those changes are:

• Adding a letter to the systems that will be designed to be generated as early as November, 2009, letting those ARRA AEI’s who are receiving subsidy for the ninth month know that unless Congress extends the 65% ARRA subsidy, that month will be their last month to receive it. This letter will illustrate what the post-ARRA premium for each QB will be. New coupons or premium notices will optionally print for each QB at the same time, showing the post-ARRA premium.

• Automatically denoting the QB record when an AEI is no longer eligible for subsidy after their nine months of subsidy has expired.

• Providing you a new Option in the system to allow for your interpretation of the ARRA law as it relates to COBRA continuees who lose coverage on December 31, 2009. Some administrators have the opinion that those whose first day after loss of coverage is January 1, 2010 are eligible to become AEI’s; others believe those QB’s are not eligible for the subsidy. Whichever position you take, by setting the new Option accordingly, our systems will send/not send the appropriate notices and do the resulting premium billing.

We at Travis are also aware of speculation that the ARRA subsidy may be extended. While it is impossible to know at this point whether or not Congress may extend ARRA, if they do so, we can and will provide you with a new version of either TravisCobra or WebCOBRA.com that will extend the special ARRA wording on the COBRA Election Notices, will include DOL-specified forms for those who lose coverage after January 1, 2010, and will bill subsidized premiums appropriately. Even if it is not extended, ARRA will be with us for a while longer. Those whose qualifying events occur in December, 2009 and who are confirmed as AEI’s will be able to receive subsidy in September, 2010. Both TravisCobra and WebCOBRA.com are already programmed to handle those contingencies.

We recently learned that the IRS has already begun to do “ARRA Audits” of employers who file Form 941 with ARRA deductions. During these audits, the Service appears to be interested in being given a report showing only the AEI’s name, their Social Security number, date of involuntary termination and the amount of premium that was actually received from each AEI. We hope you don’t have to endure one of these audits, but in case you do, we are currently adding an “ARRA Audit Report” to both TravisCobra and WebCOBRA.com that will display this information and be printable for whatever time period your audit covers.

We will continue to keep you up-to-date with changes we are making and planning to make to both our COBRA systems designed to help you meet the ARRA requirements. We welcome your thoughts about how we can help you more completely.

Thank you again for your continued support of Travis!