ARRA Implementation Details for TravisCobra and WebCOBRA
Category: 2009 Stimulus
Topics: stimulus, traviscobra, webcobra
We’ve published details on how we are going to modify TravisCobra and WebCOBRA to help you meet the new COBRA Administrative needs of the 2009 Stimulus Bill. Read more for details on the new Actions, Letters, and Reports in both systems. We will have the following ready for you to use by 3/1/2009 in both TravisCobra and WebCOBRA.
New Actions and Screens in the Systems
Advised Workflow for Activating Premium Reduction
Most, if not all administrators, will not know if the terminations they have proceesed were voluntary or involuntary. Since the time given to re-notify participants is so short, we recommend:- Notifying all terminations (event on/after 9/1/2008
and did not enroll in COBRA) of a possible right to enroll in COBRA as of 3/1/2009 with reduced rates. - QB returns enrollment form to the administrator.
- Administrator then verifies with the Client/Employer that the event was involuntary.
- Once verified, Administrator activates the ARRA Subsidy.
Premium Reduction Summary Report
New report to both systems that will list, by Client/Employer, the government 65% premium reductions that were used to pay premiums in a given time-frame. It will list the QB’s Name, their Identifying Number (see post about SSNs), the premium amount, the subsidy amount, and the benefit plan codes. It will subtotal by Client/Employer and give you a grand total at the end. You’ll be able to export this report to Microsoft Excel format in both systems, and can email it in the WebCOBRA Enterprise edition.
ARRA Stimulus Wizard
Wizard will be run once by the Administrator; it will pre-populate new records with a new event for eligible QBs (those who had a qualifying event on/after 9/1/2008, but who did not enroll in COBRA.) These new events will have new Election Notices and Enrollment Forms printed out, with their original event date, but a COBRA start date as of 3/1/2009. Their 60 day window will start on the later of the 3/1 or Print Date.
ARRA Stimulus Eligible – QB/PQB Record
User will go to the QB/PQB record and click on an action to “Activate ARRA Stimulus.” This will bring up a page that shows the limitations and restrictions, including asking the user to confirm the event was Involuntary Termination, and asks the user to confirm, and whether to send an ARRA Stimulus Letter and coupons.
ARRA Stimulus Opt-Out – QB/PQB Record
User can specify the date the QB wants to stop using the Government Stimulus. The 65% will no longer apply after that date. Designed for High Income individuals.
Add new ARRA Stimulus QB
Able to use QB Add Wizard to add new Event starting 3/1 for TPA’s doing takeovers, etc.
Send ARRA Open Enrollment Letter
New letter describing ability of QBs to change coverage within 90 days, but premium cannot increase over what it was at time of event.
Downloading / System Integrator
You will be able to download new QBs to be re-notified of COBRA if you’d like to. The new event type and new fields will be published in the next few days, once the format has been finalized by our development staff.
New Letters (Including Blocks and Insertable Templates)
Cobra Election Notice
New block / insertable template that will be the first paragraph in the Cobra Election Notice. It will describe why the QB is receiving a notice and how this is a new enrollment period with coverage starting 3/1/2009, but will have no coverage between event date and 3/1/2009. It will also talk about the subsidy, which they may be entitled to depending on income, and how their original COBRA end date does not extend. Then, the rest of the Election Notice will be the same.
ARRA Enrollment Form
We’ll need an enrollment form that will list out the restrictions and what they’ll be asked to pay.
ARRA Stimulus Confirmation
A letter to go out confirming the QB has been enrolled in the 65% subsidy. It should tell them that it is required for the QB to notify the administrator immediately if they become eligible to enroll in a group health plan.
ARRA Open Enrollment Letter
We need to draft a letter describing that the QB can change coverage in 90 days to another plan or coverage, provided it does not increase their premium over the amount charged as of the Event Date. Should direct them to the administrator for more information on their options. TPA’s can then edit this.
Details
- The Cobra Election Notice and ARRA Enrollment form will be initiated by the user completing the wizard and then accepting letters or running AP. A user can always reprint and recreate their Enrollment packet in the future.
- QBs/PQBs who are re-notified will have two records in the system, one for their original enrollment period, and one for their new enrollment period starting 3-1-2009.
- If a QB/PQBs was still in their enrollment period, and was re-notified, the system will term their existing record. You will be able to always go back to the original record and reinstate it, enrolling as of their loss of coverage date. The QB will still be eligible for the 65% premium reduction if you enable it on their record.
Update 02/20/2009: We have posted detailed on how TravisCobra and WebCOBRA will calculate the premium subsidies. We also removed the qualification that a QB who previously elected COBRA and terminated would not be eligible. We’ll let you select those QBs during the wizard and make that determination yourself.
47 Responses to “ARRA Implementation Details for TravisCobra and WebCOBRA”
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February 19th, 2009 at 12:57 PM
How will the system handle those who are on a severance package and pay subsidized rates either prior to or after 3/1? We have clients who allow participants to pay the EE rate during their time on severance. If the severance begins 2/1 and ends 4/1, will the system know to begin billing the 35% subsidy as of 4/1, but for only 8 months?
Also – will the 2% fee be based on the full premium rate or the 35% amount. Example, if the 100% base rate premium is $1000, will the 2% fee be $20 or $7?
February 19th, 2009 at 01:24 PM
@Cara: We’ll be posting an update on premium calculations with subsidies soon. In your case, yes, the system would begin charging the QB following the end of the 100% subsidy. It will also know which months can be subsidized (9 months following March 2009). So the system won’t extend the premium reduction past when the government says it can. The 2% fee will be based on the full premium amount, in your example $20.
February 19th, 2009 at 02:34 PM
Will there be a report to document the number of notifications re-mailed per client in TravisCobra?
February 19th, 2009 at 02:51 PM
Notifying all terminations (event on/after 9/1/2008 and did not enroll in COBRA) of a possible right to enroll in COBRA as of 3/1/2009 with reduced rates.
Will these notifications also be available to those who are currently enrolled effective 09-01-08 as they too are qualified for the reduced rate.
February 19th, 2009 at 04:03 PM
Please clarify in detail how Travis will handle the 2% admin fee under the subsidy bill. I’m getting mixed reports on this issue. Is the 2% fee being split (35/65) under the subsidy? The bill states participants can not be charged more than 35% of the applicable COBRA premium. Note: They used “applcable premium” and not insurance premium.
February 19th, 2009 at 04:22 PM
@Jodi: Yes, you’ll be able to run the Notification Issued Report and specify re-notifications
@Elizabeth: Yes, you’ll be able to send out ARRA Enrollment Forms to your existing enrolled QBs. Alternatively, if you know the event was involuntary termination you can just turn it on.
@Jon: That’s because the issue has been evolving and gained clarification from the IRS. We will post examples soon, but the Admin Fee and Employer Subsidies will both be combined to form the “premium”; then, we’ll calculate 65% from that. So with a $100 plan and 2% admin fee, the “premium” will become $102, the QB will pay $33.70 and the administrator will pay $66.30
February 20th, 2009 at 07:04 AM
I have a question regarding the phrase in the bill, “involuntary termination”. Is that specific or does it mean, “involuntary qualifying event”? For instance, I have a client who has a number of people on layoff but their benefits have been terminated while on layoff. So, while this group has not suffered an “involuntary termination”, they have experienced an “involuntary qualifying event”. Help!
February 20th, 2009 at 08:54 AM
Jesse, I have heard two diffrent answers here on this issue. If someone termed 9/15/2008, then enrolled in COBRA and was later termed for lack of payment as of 12/31/2008, will this member be elibigle to re-enroll as of 3/1/2009?
February 20th, 2009 at 09:14 AM
It is my understanding that only Qualified Beneficiaries are entitled to the subsidy. Is Travis going to be able to calculate the subsidy for only QB when we have either a domestic partner covered or a non QB on the QB coverage? Also, in reference to Adella’s question. It is our understanding that the answer is the QB will be able to re-enroll. So is Travis going to handle this situation as well?
February 20th, 2009 at 09:15 AM
If someone elected COBRA as of 1/1 for dental and vision only, but declined medical coverage would they be eligible to pick up the medical as of 3/1? If so, how would we know that someone is eligible for medical coverage as of 3/1 if they did not initially elect it – the benefit disappears when you drop from COBRA.
Also, I know the subsidy is for Medical only, but for someone who did not elect coverage and now has the option to pick up the coverage as of 3/1, if they originally had dental coverage would that also be available for them to pick up at this time but at the full rate?
February 20th, 2009 at 09:41 AM
Second question- Looking at what Cara is saying, is this subsidy only for medical. I have not seen that clarified anywhere, maybe I missed it. Can someone please confirm.
February 20th, 2009 at 10:21 AM
@Jim: The law simply states Involuntary Termination. You may need to obtain a legal opinion on your case; it would seem that the combination of layoff + loss of benefits would be an involuntary termination, but that’s only my opinion.
@Adella: It looks like that got sorted out in Conference. While the Senate bill precluded people who had elected COBRA, the final bill changed the language slightly. Based on that and some of the guidance from the IRS on Thursday, It looks like yes, member can re-enroll.
@Karen: You can enroll anyone you want to, so yes. We believe the subsidy is based on the entire premium due to the QB. If you want to charge different amounts to non-QB or domestic partner, you’ll need to set them up as a different group and have them be non-eligible (if that’s how you interpret the law)
@Adella: Based on new Guidance, the subsidy appears to be all plans except FSA (and most likely HRA/Life insurance plans).
February 20th, 2009 at 11:32 AM
Jesse, can you tell me when all these additions/changes will be out on Web COBRA? The website is saying before 3/1/09, is this still correct and is there a set date at this time? I am hoping to be ahead of the game a little and want to get out the notices to all current COBRA members and all memebrs that could have been eligible. I am anxious to get this started.
February 20th, 2009 at 11:38 AM
@Adella: Yes, 3/1/2009 is still our plan, barring any new guidance that forces us to start over.
February 20th, 2009 at 12:13 PM
Jesse, we heard that this subsidy does not include dental, but your response to Adella said it appears to cover all plans but FSAs, can you point us to the “new Guidance”. We are trying to determine what plans it truly covers.
February 20th, 2009 at 12:22 PM
If ARRA takes into account employees invol termed back to 9-1-08,but the 65% subsidy goes into effect 3-1-09, how do we treat the period from 9-1-08 to 3-1-09. Charge the regular amount w/o the 65% for 6 mos. So they would need to pay 6 mos of premiums at 100% to take advanage of the subsidy?
What will be the first notice COBRA administraor would need to send to PQB’s? Will Travis have a letter available to send to our clients explaining what we COBRA administaators are doing?
February 20th, 2009 at 12:43 PM
Hi Jesse – can you please reply to my question (# 0) that I left at 9:15 am? thanks!!
February 20th, 2009 at 01:24 PM
@Cara: This is only my opinion.. I don’t think a QB could throw away their rights to the subsidy… If someone dropped Medical, seems that would be the same if someone dropped COBRA altogether, which is that they can re-enroll as of 3-1-09 and get the subsidy.
@Hilda: If a QB is on COBRA from 9-1-08 through 3-1-09, you’ll charge them the regular amount. However, if they are re-enrolling in COBRA as of 3-1-09, the won’t have insurance from sept through march, so you wouldn’t charge them anything.
@Julie: The final bill kept the ‘only medical’ language for the Plan Enrollment, but it isn’t there regarding the Premium Reduction. If we see the guidance given on the conference call put to print/web we’ll link to it
February 20th, 2009 at 02:58 PM
Can you give us any indication if medical, dental and vision will all be included in stimulus. We have some groups that offer as a “combo meal” and others who offer ala carte as they do with active group. Can someone just elect dental and vision and still receive the subsidy? We have conflicting info on this.
February 21st, 2009 at 02:29 PM
@Cherie: TravisCobra and WebCOBRA will apply the subsidy to medical/dental/vision plans, if the QB has been approved for ARRA Subsidy. You should seek counsel’s advice on only dental/vision, but the program will allow you to enroll someone who only has Dental/Vision into ARRA.
February 23rd, 2009 at 05:45 AM
Based on your response to Cherie, how will the enrollment option be handled on notifications to the participants? Will TravisCOBRA offer options to make changes to Medical, but not to dental and vision plans?
February 23rd, 2009 at 08:14 AM
@Cara: That specific and rare example will need to be handled by the administrator. If a QB only has Dental/Vision, administrators should make the choice whether or not to enroll them in the ARRA subsidy.
February 23rd, 2009 at 01:41 PM
Jesse – I feel like there is conflicting information and details, if the subsidy applies to all plans then wouldn’t we offer the opportunity to reenroll in the ARRA subsidy even if someone just had dental and or vision? My question was related to the notification we send to participants – If they can make changes to Medical, but not dental and vision plans, what will the notice look like? will you include premiums for Dental and vision? How soon do you think we will be getting the upgrade? Is there anyway I can contact you directly to quickly discuss some of these items?
February 23rd, 2009 at 01:48 PM
@Cara: TravisCobra and WebCOBRA will give you the ability to notify all QBs who had an event between 9/1/2008 and the present. As the administrator, it will be your duty to verify any enrollment forms that come back, including verifying that the event was Involuntary, and in your case, whether you believe only vision/dental QBs should receive the subsidy.
We are looking for an installation this weekend, so it’ll be available on 3/1/2009. We will post sample letters this week for you to look at, and to plan your modifications.
February 23rd, 2009 at 02:02 PM
When do you think the report that Web COBRA is offering to help companies with the payroll deductions be ready, by 3/1/09 also?
February 23rd, 2009 at 02:53 PM
Is there anywhere that we can look to for confirmation that it applies to more than just the Medical plans? We have seen conflicting information and if it is going to apply to dental, vision, etc we want to make sure that we get out an update.
February 23rd, 2009 at 03:22 PM
Hello again, What if someone had their hours cut involuntarily and due to that reduction in hours, they lost benefits involuntarily?
February 23rd, 2009 at 03:25 PM
Hi – Is anything changing on the interface file to accommodate the new laws (i.e. termination codes, etc.)?
February 23rd, 2009 at 03:29 PM
@Adella: the Premium Reduction Summary Report will be part of the update. It’ll be blank until QBs start to be ARRA Subsidy enabled though, but it’ll be there
If there’s anyone with documentation for @Korri’s question, please post here
@Nancy: The law stated, “Involuntary Termination” as the event. In my opinion, loss of hours would not qualify, although you may want to seek counsel’s advice on that
@Eli: Yes, we are modifying the downloader and system integrator, and will publish those specifications as soon as they are ready.
February 24th, 2009 at 12:56 AM
What about event codes in Travis of “9” Loss of Coverage – this is used for many types of involuntary terminations – wil Travis cobra be identifying these for the automatic coverall of the letter notifications
February 24th, 2009 at 08:29 AM
@Mabel: Event Code 9 will be included in the QBs who are re-notified
February 24th, 2009 at 12:52 PM
We just have some more specific questions/clarification on the second notices. Will we be in control as to when this correspondence creates and is printed? I am understanding that if we run a wizard to create the correspondence and all new qb records this is going to tie up our correspondence system for quite awhile is there an updated time frame as to when we can start this? Will we have the opportunity to edit any correspondence prior to this auto run or will that only be on an ongoing basis.
I am not seeing any specific clarification on what status are included in this auto second notice. Is this one notice for both enrolled, notified waiting response and terminated qb’s or will the enrolled qb’s only receive a simulus letter and coupons?
Now that we are getting close to March 1st we are really looking for more specific clarification on what and when everything will be ready to go. Are we expecting that the subsidy button will be in place on Monday morning the 2nd of March? Thanks so much.
February 24th, 2009 at 01:58 PM
What about overage dependents and divorce? Are they eligible for the subsidy?
February 24th, 2009 at 02:08 PM
@Lorie: You’ll be able to run the re-notification wizard whenever you like, and for which sets of Client/Employers you want. You’ll have the opportunity to modify letter sets (TCFW) or use the IWP (WebCOBRA) prior to running the wizard.
Yes, you’ll have the wizard and actions over the weekend.
@Rose: In my opinion no, only Involuntary Termination of Employment.
February 24th, 2009 at 06:46 PM
Can Travis provide a notice to participant towards the end of the subsidy notifying them that as of (date) their premiums are not longer subsidized and they will be required to pay the full cost of the premiums for the remainder of their COBRA continuation period? I think a lot of participants will continue to pay the reduced premium unless we tell them otherwise.
February 24th, 2009 at 09:36 PM
Today I was part of a webinar sponsored by EBIA and they suggested the re-notification should be mailed to all QBs for all qualifying events (term, reduction in hours, death, divorice, and loss of dependent status) retro to 09/01/08. This statement was challenged during the discussion as everyone understands only involuntary terminations are eligible under the Act. EBIA suggested per the regulations we need to inform everyone so they are informed of the regulations/subsidy. Participants might have been assigned the incorrect event type or term date and they need to be informed so they can appeal with the DOL if needed.
Will the re-notification generate for all qualifying event reasons? If not, please list all qualifying events Travis will generate for. What do you think about EBIA’s statement of total renotification?
February 25th, 2009 at 09:00 AM
Hi Jesse:
Will we be able to run the Stimulus Wizard by client, or will this be a one time process through Admin? Also, the Premium Reduction Report, will this be a client specific report as well, or will this have to be run through Admin.
February 25th, 2009 at 09:41 AM
Will there be a waiver form for those income phase out QBs that choose to permanently waive the subsidy/assistance, as well as a confirmation letter for this waiver. How will we track thses in TRAVIS COBRA?
February 25th, 2009 at 09:52 AM
Hi All!
@Cara: I think that’s a good idea, and if the government doesn’t extend the subsidy past the current 9 months, we’ll add a letter around September in an upgrade that’ll go out letting them know of the subsidy ending
@Jon: It sounds safer but in my personal opinion possibly overkill. If you want to do that, you’ll need to manually re-enter those reduction/death/divorce events with the 3/1 start date
@Jodi: Yes, you’ll be able to run both the ARRA Renotification Wizard and the Premium Reduction report by employer (or by all employers / admin level).
@Jodi: We won’t have a waiver form out of the gate; if a high income individual wants to opt out, they’ll need to get you that information somehow, and you can go to the QB/PQB record and opt-out as of a given date then.
February 25th, 2009 at 10:55 AM
For any TPA out there
Has anyone come up with a fee structure to charge back to clients for this??
February 25th, 2009 at 11:14 AM
I think Travis will need to notify everyone back to 09/01/08 no matter the QE reason.
February 25th, 2009 at 11:25 AM
@Jon: To answer your questions, no we do not take on any liability, as we provide tools for administrators to use.
If you would like to notify all events, you are welcome to do so; our automated methods that help you re-notify involuntary terminations by pre-filling new events for you will not re-notify non-termination methods.
February 25th, 2009 at 12:10 PM
We,too, are being advised to notify everyone that has had a Qualifying event. Did I understand correctly that the wizard would not handle this and we would have to touch all of those records. I hope Travis will reconsider and allow us to choose all events.
February 25th, 2009 at 12:57 PM
Will the letter offering enrollment in the lower cost plan be optional? Since it is at the employer’s determination not all of our clients are going to offer the choice.
Also, is it possible to desigh the ARRA Wizard to allow us to select the QE events we want to have the records repopulated for? We could then select reduced hours, Event 9 which we use for lay off and so on. That would satisfy each enterpretation of involuntary termination.
February 25th, 2009 at 04:09 PM
@Lyn: I’m not sure what you mean; but if you want to have the ARRA Enrollment Form not show rates, you could edit it and remove that section of the letter.
February 25th, 2009 at 04:18 PM
I was referring to the Open Enrollment Letter at the top of this blog. The letter allows the QB 90 days to elect a lower cost option. Will this letter be optional.
February 25th, 2009 at 04:25 PM
@Lyn: completely optional, it’ll be a manual letter that you can either schedule or not.