ARRA COBRA Administration - March Changes
Category: 2009 Stimulus
Topics: stimulus, traviscobra, webcobra
The majority of our customers have now upgraded to version 8.3 of TravisCobra. WebCOBRA will be upgraded this weekend!
Over the last two weeks, some views have changed and we’ve added some features—here’s what’s coming in the next week.
WebCOBRA
In WebCOBRA, the Renotification Wizard has been enhanced to pull more events than just Terminations. If a QB was entered as a non Termination, such as Death, and it was a secondary event, WebCOBRA asked you to enter the original event type and date. If that original event was Termination and the qualifying event date was on or after 9/1/2008, that QB will be notified.
In the second iteration of ARRA changes to WebCOBRA, we’ll be adding the capability to send an ARRA Enrollment Form to any enrolled QB who had an event date after 2/17/2008. This idea popped up on the blog comments so we think that’s great.
TravisCobra
All Event Notification
You will be able to run the Renotification wizard, either for the first time or again, and choose all events that you want to include. This should satisfy the users who want to over-notifiy just to be safe.
Premium Reduction Report
We’ll be adding more information to the Premium Reduction Report, including the event date and the number of dependents on the plan. We’ll post that here and in the Sample COBRA Notices Post.
DOL Changes
When the DOL does post their model notices, we’ll post them here and update our sample and default notices as well. We can then decide if we need to re-notify all QBs with events after 2/17/2008 or not.
42 Responses to “ARRA COBRA Administration - March Changes”
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March 6th, 2009 at 04:27 PM
Excellent. Thanks for these enhancements.
Do the changes to TCOBRA above mean that you will be releasing a version 8.4 next week?
March 6th, 2009 at 04:32 PM
@Chuck—the version will actually be 8.3.0.7, but yes. Will be made available next week.
March 6th, 2009 at 06:45 PM
I realize this may be out of your realm of knowledge, but am hoping you may have come across an article regarding the situation below:
Termed employee was offered a severance package in which the prior employer paid for the first three months of COBRA. Starting in April, the participant will have to pay for himself and family. His wife and he are eligible for insurance under her plan. But, the qualifying event happened 90 days prior. At this point, are they eligible for the subsidy until it is open enrollment again at her company?
March 7th, 2009 at 07:49 AM
@Rebecca: if he is eligible to enroll in his wife’s plan today, then in my opinion, he would not be eligible for the ARRA subsidy.
March 7th, 2009 at 07:29 PM
Got the update installed and notices sent to ALL people with a QE of “termination” from 9/1/08. I since know that some are NOT subsidy-eligible, and want to post their March unsubsidized premium payment. How do I tell the software that they’re NOT eligible and I don’t want the 65% reduction applied? Right now, even though I have NOT performed the PQB ARRA verify function on the Action screen, the scheduled March premium still reflects as reduced. I don’t see an “opt out” field in the Personal screen. Do I have to delete the “ARRA renotification” PQB record and reinstate the PQB record that was terminated by the ARRA renotification process?
Sorry if I’ve missed some instructions on this.
March 8th, 2009 at 10:28 PM
1)I see for travis COBRA there will be a way to notify everyone not just terminated, is there a way to do that in Web COBRA?
2)Will both rates subsidy and non subsidy be on the enrollment forms. I ask this because someone may be involntarily termed but does not want the subsidy, e.g. over the wage rule, is eliglbe for other coverage like Medicare, but still wants COBRA as a secondry plan.
3)How do I set up a severnce subsidy and the gov subsidy. What do I do if someone is on severence where the comp. is paying 50& of the cost of COBRA for 3 months, so the QB actually only has to pay 35% of the 50%. Is there a way in Web COBRA to set this up?
March 9th, 2009 at 08:25 AM
We entered a test employee with a termination date of March 2, 2009 in our system. We checked the ARRA eligible box and the ongoing premium calculated correctly. The prorated premium for March was about .35 higher than it should have been. Is there an issue with the proration function in 8.3.06?
March 9th, 2009 at 08:29 AM
@Chuck: If you are re-notifying PQBs, then they are (potentially) eligible for the subsidy. If they are not eligible, then you should not enroll them as they turn in their ARRA Enrollment form.
@Adella: I answered your question (posted in two locations) on another post. Please don’t do that again.
@Laura: No issues; and you’ll need to contact support over questions like that.
March 9th, 2009 at 09:42 AM
Three questions:
I ran the re-notification process.
1) The letter that printed out for an employee that was already on COBRA was the ARRA Open Enrollment letter. Is this the standard letter sent to anyone that is already on COBRA?
2) For an employee that was terminated on 12/18/08, and had a loss of coverage date of 1/1/09, the new re-notification Election Notice shows the loss of coverage date as 3/1/09. Is there a way to change the macro to show the original 1/1/09 date?
1) I don’t think block 38 should print on the enrollment form if a new termination has not been marked as stimulus eligible (same logic as block 37).
March 9th, 2009 at 10:38 AM
@ Brad: 1) Yes, the ARRA Open Enrollment Letter is the standard letter for anyone already enrolled in COBRA, but in TravisCobra, it prints the ARRA Enrollment Form after it. 2) If a QB Is non-commenced, then their coverage is going to start at 3/1/2009. 3) Please call Travis Support so they can diagnose what’s going on.
March 9th, 2009 at 12:45 PM
When running the AP after the re-notification process, does the system create the letters in alpabetical order? We killed our AP process at 70% which we were at the “P”, but when we go to view those that updated before the “P” there are no letters.
March 9th, 2009 at 01:18 PM
@Karen: You have the option for letters to print by either SSN or Alphanumeric during the AP Process. If you are experiencing problems, please contact Travis Support.
March 9th, 2009 at 01:54 PM
Jesse, If we don’t send a letter to all “potential” AEI’s, it would be nice to have a letter on the front end of Travis that would allow us to select the individual and send them a letter informing them about ARRA but telling them that we have determined that they are not eligible and inform them of their appeal rights to the DOL.(When DOL publishes appeal process) It would also be nice to have that letter available for current COBRA enrollees that are not premium assistance available.
March 9th, 2009 at 02:01 PM
We processed the upgrade and ran the ARRA renotification Utility. Can you verify that the following results are correct: Pending individuals – Printed entire enrollment notification and if the termination date was prior to February, the enrollment form uses the coverage event date as the date they lost coverage and the rates on some forms show the subsidized and some do not. Enrolled individuals – Shouldn’t the date on the enrollment form display 3/1/2009 not a previous loss of coverage date?
March 9th, 2009 at 02:14 PM
@ Mike: For all Ideas that could enhance the system, please post them to the Travis Ideabook at http://ideabook.travisoft.com/ so that our other customers can view and vote on your idea!
March 9th, 2009 at 02:24 PM
It seems that both systems will be sending out ARRA enrollment forms to all new QB’s that we load as “180, Stimulus Eligible” and code with a “T” for true.
My question is: How do these QB’s enroll in COBRA if for some reason they do NOT want the subsidy? The only enrollment form the systems will give them is the ARRA enrollment form and it does not show the normal COBRA rates.
Shouldn’t there be form for these QB’s to use to complete normal COBRA enrollment even though we have told them (and the system) that they are ARRA eligible? And shouldn’t that form show the normal COBRA rates?
Thanks
- Chuck
March 9th, 2009 at 02:39 PM
@Nancy: At the time of Re-Notification 1) Pending Individuals – Their Payment Due Date will be the First Day after Loss of Coverage, enrollment period will be from 03/01/2009 OR the date the new COBRA Election notice printed, whichever is later, and their existing Enrollment period will be ended and their prior pending record will be terminated. 2) Non-Commenced Individuals – Payment Due Date will be 03/01/2009 and their Enrollment period will be from 03/01/2009 OR the date the new COBRA Election notice printed, whichever is later.
March 9th, 2009 at 03:44 PM
@Chuck: We do understand that they have the ability to elect regular COBRA; however, marking them as ARRA eligible prints the ARRA enrollment form showing the subsidized rates. An alternate to this would be to add wording informing the participant that they do have the ability to elect out of ARRA and obtain more information by contacting XXX at XXX.
March 9th, 2009 at 05:10 PM
What is the logic behind asking the employer to designate the termed employee (QB) as ‘involuntarily’ termed (or voluntarily termed) for QB’s with a 2/17/09 QE date forward? If the re-notification process goes to all QB’s that termed – why not just send include the subsidy informationin in all Term QE letter sets after the 2/17/09 ARRA enactment date?
March 10th, 2009 at 07:19 AM
I added a test QB with term date 3/6/09. In prior activity, I marked the choice ” Send ARRA enrollment form”. I printed the COBRA packet, and the normal COBRA notice printed, with no mention of the ARRA stimulus. The ARRA Enrollment form printed, which is great. The problem is, there is no description for the QB of what the ARRA is. Am I doing something wrong? When I look in History, it shows “QB Stimulus Notified” and “Eligiblilty notice printed”. But they weren’t. Should I be talking to support, or doing the process differently? Others must be experiencing this as well.
March 10th, 2009 at 08:29 AM
@Lisa: We aren’t able to diagnose potential support issues on the Blog. Please contact Travis Support regarding this issue. Thanks!
March 10th, 2009 at 09:14 AM
@Keith: The reason is because when you are adding a QB, you might already know at the time of that the QB is not eligible for ARRA, meaning the QB quit. ARRA is is for involuntary terminations. The Re-Notification process includes all existing QBs in the system because we don’t know if at the time of the event if it was voluntary or involuntary, so that is why we pick up enrolled QB’s.
March 10th, 2009 at 11:42 AM
We have half of our clients stating that the QB’s can switch plans. I don’t show anywhere on any of the forms that it shows this. Is there a possibility to have a check box that can be checked to give them the option to switch plans? Please advise. Thank you.
March 10th, 2009 at 01:21 PM
@Rose: The ARRA Open Enrollment Form and the ARRA Enrollment Form are the ones you need to use. The plans aren’t listed; however, you do have the ability to add wording inviting them to contact XXX at XXX about possible plans that may be available.
March 10th, 2009 at 03:17 PM
These forms do not show options or list each plan. We are on the newest version of Travis, but when I go into letter writer I don’t see the re-notification letter. I also have a test person terminated with a QE of 9/1/08 and tried to say ARRA eligible, but no letter was produce. Is this something for Support to handle?
March 10th, 2009 at 03:32 PM
@Rose: Yes, please contact Travis Support at your earliest convenience.
March 10th, 2009 at 05:45 PM
When will I be able to get the release 8.3.0.7?
March 11th, 2009 at 08:37 AM
8.3.07 is currently available. Simply go the .ftp website you received in the 8.3 email and you will be able to download the patch there!
March 11th, 2009 at 08:45 AM
@Julie: You will need to contact Travis Support.
March 11th, 2009 at 10:29 AM
If the update does not work on my 8.0 version, are there manuel changes I can make to help administer the new ARRA changes? Do I need the update?
March 11th, 2009 at 10:45 AM
@Danette: Please contact Travis Support so that they can assist you with your upgrade!
March 11th, 2009 at 12:40 PM
Will TC Web be updated with a check box or a new code where clients can enter whether a termination is voluntary or involuntary?
March 11th, 2009 at 12:43 PM
Will final regulations be posted on the blog or sent to us via email? I still have some concern regarding my clients that have only dental/vision plans. We need clarification as soon as possible. Thanks!
March 11th, 2009 at 02:03 PM
I ran the Utility for a test group, and a different re-notification letter printed from the one you posted here on the blog. Is there a reason the first couple of paragraph’s were removed from the letter? Thank you for all your time.
March 11th, 2009 at 02:37 PM
@Rose: Please contact Travis Support regarding this. We can’t diagnose potential issues over the Blog. Thanks!
March 11th, 2009 at 02:49 PM
@Elizabeth: Once we see the model notices from the DOL, we’ll evaluate upgrading TCIAM at that point.
March 11th, 2009 at 02:51 PM
@Elizabeth: As more information, including regulations and model notices, become available from the DOL, we will Blog about those. For specific information on plans and regulations, we recommend you contact the DOL directly.
March 12th, 2009 at 08:21 AM
Sarah if we enter someone in the system as an involuntary termination the ARRA letters automatically generate. It seems these letters are not ready yet, so why are they generating. The total on the enrollment forms are not calculating correctly nor is the Premium Computation or Enrollment Teir Fomrs. I have called Support about this but they just said it is a known issue and they are not sure why it is happing and are looking into it. Should we enter all our terms as resignation so the ARRA forms do not go out? Also you mentioned there was an opt out option on Web COBRA. I activated someone as ARRA and that option is not available on my Web COBRA.
March 12th, 2009 at 08:46 AM
@Adella: Please contact Travis Support regarding specific issues you are having. We are unable to diagnose potential problems over the Blog.
March 12th, 2009 at 01:26 PM
Hello, all ~ We attended a webinar yesterday that was offered thorugh SHRM. The faciliator stated that a reduction in hours (resulting in a loss of coverage) SHOULD be considered for subsidy payment. I have other information from other sources that stated that this WOULD NOT be considered an involuntary Term. Has anyone received any guidance from the DOL or IRS on this topic?
March 12th, 2009 at 03:35 PM
I have heard from a webinar that our company attended that it would not be considered involuntary, because the regulations state loss of coverage due to termination from the company not loss of benefits. I dont know if that really is correct, but that is what we are going with until the DOL defines involuntary termination, hopefully.
March 13th, 2009 at 04:11 PM
In a convesation with a COBRA benefits specialist at the Ohio Regional Office of the DOL/EBSA last week I was told that the DOL does not consider reduced hours as eligible for the subsidy. I am waiting for the DOL Model Notice to see if that has changed.