DOL Releases COBRA Model Notices
Posted on March 19th, 2009 by Travis.Development | 36 comments »
Category: 2009 Stimulus
Topics: arra, cobra, stimulus, traviscobra
Category: 2009 Stimulus
Topics: arra, cobra, stimulus, traviscobra
The Department of Labor has released model COBRA notices designed to help COBRA Administrators comply with ARRA, the 2009 stimulus.
There are four DOL ARRA COBRA notices posted at the DOL’s website
- General Notice (Full version)
- General Notice (Abbreviated version)
- Alternate Notice (State Continuation)
- Notice in Connection with Extended Election Periods
- Inclusion of a Summary document
- Three page form entitled ‘Request for Treatment as an Assistance Eligible Individual”
We are evaluating the model notices right now, and will post our plan for system modifications either today or tomorrow.
36 Responses to “DOL Releases COBRA Model Notices”
Comments are closed for this article.
March 19th, 2009 at 11:09 AM
The current ARRA COBRA notices developed by Travis does not calculate and provide both the AEI subsidized premium and the full COBRA premium for non-AEI eligible individuals. The DOL Model Notice includes both. Also, the election format for the subsidy is much clearer in the DOL Model Notices. I would like to see Travis make these modifications.
March 19th, 2009 at 12:00 PM
It seems that there are also some changes in the Trade Act of 2002. Is this being addressed with all the other changes?
March 19th, 2009 at 12:51 PM
We are wondering if two election notices will be required in the Enrollment package. One electing COBRA as well as the stimulus and one electing COBRA but not the stimulus.
Thank you!
March 19th, 2009 at 12:56 PM
@David: TravisCobra does offer both premium amounts in the 8.3.0.08 release, and the WebCOBRA.com system has also been programmed with that feature. It is currently being tested in WebCOBRA and the hotfix containing this feature should go up over the weekend.
March 19th, 2009 at 12:57 PM
@Janet: Yes, we will be working on the TAA changes in the upcoming weeks.
March 19th, 2009 at 01:08 PM
We have the COBRA version 8.3.0.08. What merge fields contain the two different premium amounts? Can these be used in any letter or only certain letters?
March 19th, 2009 at 01:26 PM
@Elizabeth: We believe that two notices won’t be required because the enrollment package will include the rates with the stimulus and the rates without the stimulus.
March 19th, 2009 at 01:27 PM
Sarah, Will the release provide two election forms? One electing COBRA and the stimulus and the other electing only COBRA? I believe even if a member is not eligible for the stimulus they are still able to re-enroll, is this correct?
March 19th, 2009 at 01:51 PM
It appears the DOL has subtly expanded on the definition of “involuntarily terminated” on the Request for Treatment as an AIE by listing a reason for denial as “loss of employment as voluntary”. As an employer, I have access to the reason for termination of employees. However, based on the reason for denial it appears the correct assumption would be the only individuals that wouldn’t gualify due to termination would be those that resigned and gross misconduct giving consideration to poor performance, attendance, punctuality and health. I have sent an email to DOL asking if these events would be considered voluntary or involuntary. I’ll be glad to post should I receive a response. Also, the footnote on the summary page still does not clarify whether the subsidy applies to dental and/or vision when elected in conjuction with health coverage for stand alone plans. I requested clariifcation on that question as well.
March 19th, 2009 at 01:52 PM
@Rebecca: It is B039 and can only be placed on the ARRA Enrollment Form.
March 19th, 2009 at 02:24 PM
Can the ARRA Payroll Premium Reduction Report be run quarterly for a client and then is it totaled so they can identify what the total amount of subsidy they can use as a credit.
March 19th, 2009 at 02:31 PM
In regards to B039 – was there an instruction pdf that went along with the 8.3.0.8 update? If so, where can I find it? This is the first I’ve heard of the B039.
March 19th, 2009 at 02:48 PM
We do not have 8.3.0.08, why not?
March 19th, 2009 at 03:08 PM
@Rebecca: An updated .pdf will be included in the next TravisCobra release. You can find it in the Block selection for the ARRA Enrollment Form.
March 19th, 2009 at 03:09 PM
@Thom: You can download the patch for TravisCobra 8.3.0.08 from the FTP site that you downloaded 8.3 from.
March 19th, 2009 at 03:45 PM
@Cindy: Yes, the report can be run via date range so you can run the report monthly, weekly, quarterly, etc. The report also totals the Stimulus that was applied.
March 20th, 2009 at 07:47 AM
We have received information from our legal counsel that tells us that the dental and vision does not qualify for the subsidy if it is not bundled with the health insurance. Will you be addressing this with they way that TravisCOBRA figures the premium? right now it looks as though the subsidy is being taken for all plans. Thank you.
March 20th, 2009 at 09:36 AM
@Elizabeth: Yes, even if a QB is not eligible for the stimulus, they are still able to re-enroll.
March 20th, 2009 at 09:40 AM
Has the most recent Travis COBRA application been updated to support the recent Subsidy COBRA changes? How do we go about applying the most recent system updates to our Travis COBRA application? We have not received a disk or any any other form or communication explaining steps we should follow if we need to download the updated Travis COBRA software.
March 20th, 2009 at 09:51 AM
My question has to do with the timing requirements of the re-noticing. According to the DOL website, there are 3 notices to go out: 1-to all QBs regardless of type of qualifying event commencing 9/1/08, 2)-notices to QBs who are currently enrolled in COBRA and 3)-the special election period notice for assistance eligible individuals who did not elect or have discontinued COBRA coverage. I see that the notice option 3 has a requirement for mailing out by April 18. What are the timelines for the mailing of the other two notices?
March 20th, 2009 at 10:24 AM
We downloaded the patch on March 19th. I did not get any instructions as to what changes were made by the patch. Will the “patch” go back and offer COBRA again to everyone that this applies to?
March 20th, 2009 at 12:49 PM
@Tammy: We are going to add an option where you can choose to add the subsidy to the dental and vision plans or not.
March 20th, 2009 at 12:50 PM
According to the DOL, we must send the ARRA notice to all QBs who experienced a qualifying event at any time from 9/1/08-12/31/09, regardless of the type of qualifying event. This means that we must notify QBs with events other than termination. Will Travis COBRA modify the ARRA notification process to include all COBRA events? Will you also modify the process to allow for mailing the different model notices based on the four versions issued on 3/19/09?
March 20th, 2009 at 12:50 PM
@Claudie: You can contact Travis Support and they instruct you on how to update your system.
March 20th, 2009 at 12:55 PM
@Kathleen: We recommend following the same April 18th date for notifying existing enrolled QBs about ARRA.
March 20th, 2009 at 01:15 PM
@Leslie: Modification has already been made to both TravisCobra and WebCOBRA to include all COBRA events in the re-notification process. The Travis team is also currently working on updating our systems based on the DOL notices, which were released earlier this week.
March 20th, 2009 at 01:19 PM
@Vanessa: To notify PQBs of ARRA, you have to run the Re-Notification Utility found under the Utility menu. Instructions for this can be found in the user manual and help system, both of which are located in the Help menu.
March 20th, 2009 at 03:17 PM
@ previous comments of Tammy & Sarah – have final DOL regulations been published? Are the individual dental/vision plans (those not bundles with medical) not eligible for the subsidy? I have 8 clients with this scenario and are waiting for final regulations before re-notifying. Please advise.
March 20th, 2009 at 03:50 PM
@Elizabeth: DOL model notices have been published and you can find them at http://www.dol.gov/ebsa/COBRAmodelnotice.html. It is our opinion that individual dental/ vision plans, those not included with medical plans, may not be eligible for the 65% subsidy.
March 23rd, 2009 at 09:10 AM
We loaded our patch 8.3.0.8 and I am looking for what exactly changed. Is there any notes other then the manual that show what should be in the patch? Please advise.
March 23rd, 2009 at 02:46 PM
Can you tell me why Travis Software is of the opinion that dental and vision plans may not be eligible for the subsidy? The language states that all benefit plans which are subject to COBRA are included. This includes dental, vision and HRA accounts regardless of whether they are tied to a medical plan. HSA’s, FSA’s and life insurance are the only plans specifically excluded by ARRA. Can you refer us to where you are seeing language that excludes dental and vision plans? Thank you.
March 23rd, 2009 at 03:26 PM
@Rose: For a complete listing you can ask Support, but 8.3.0.8 will show the ARRA Premium and the non-subsidized premium at the same time to the QB.
March 23rd, 2009 at 03:29 PM
@Lisa: You are incorrect in your statement that Travis thinks dental and vision are not eligible. We believe that Dental and Vision are included, but some administrators disagree. We are working to allow administrators to configure which plans are eligible.
March 24th, 2009 at 09:36 AM
I’m very confused on the dental vision plan issue. Sarah, on March 20, 2009 at 3:50PM in answer to a post from Elizabeth you state: “It is our opinion that individual dental/vision plans, those not included with medical plans, may NOT be eligible for the 65% subsidy.” I asked you for clarification as it seems clear that dental and vision plans are included. Your answer on March 23, 2009 at 3:29 states that I am incorrect in my statement that Travis thinks dental and vision are NOT eligible. I am more confused after this response than I was to begin with. Can you please clarify? Thank you.
March 24th, 2009 at 10:02 AM
@Lisa: For clarity, Travis believes that if dental and vision plans are bundled with medical plans, it is clear that they are eligible for the 65% subsidy. However, if you are dealing with only vision/dental plans, not bundled with a medical plan, they could possibly not be eligible for the subsidy. We are advising people to seek individual council on this particular topic.
March 24th, 2009 at 10:19 AM
Just so everyone is aware I received a call from the DOL, and they answered my questions about stand alone plans. They stated that stand alone dental and vision plans are eligible. Everyone can decide for themselves.