ARRA COBRA Reporting Requirements Take Us Back in Time
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.
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