Travis Software Official Blog

Over the past ten years, particularly since the passage of HIPAA and several state privacy laws, many, if not most, administrators have been moving away from identifying COBRA QBs by their Social Security number. The American Recovery and Reinvestment Act of 2009 (ARRA) is taking all of us a step backward into the past with its reporting requirements regarding Assistance Eligible Individuals (AEIs) who receive COBRA premium subsidies.

In fact, in our TravisCobra and WebCOBRA systems we do not require the SSN in order to add a QB to the system, and typically suppress the printing of SSNs on reports. Other identifiers, such as the “QB ID,” have been employed as primary identifiers for QBs.

However, now that the ARRA has created government subsidies of COBRA and state continuation plan premiums for up to nine months, employers and other “payees” who take credits against their payroll tax deposits to recover the subsidies of premiums must report to the Federal government about those subsidies.

The key identifier to be used in that reporting is the Tax Identification Number (in almost every case the Social Security Number) for the AEIs. We are recommending you follow one of the following two practices:

1. Employers and administrators using TravisCobra and WebCOBRA.com will need to make sure that any person certified as an AEI has a SSN stored in the system. The Premium Assistance Summary Report that TravisCobra and WebCOBRA will produce, and which payees can use as a guide for justifying the payroll tax credits they take, will have to list those SSNs.
2. Employers and TPAs produce the Premium Reduction Summary report and export it to Excel, using only the QBID. The employers receive the Excel document and replace the QBID with their SSN and provide the report to the government with the SSN attached.