Employers must act immediately to change their COBRA policies and procedures in order to comply Temporary Extension Act of 2010, which changes the COBRA premium subsidy that was created by the American Recovery and Reinvestment Act of 2009 (ARRA).
Under the Temporary Extension Act, the length of the subsidy period was extended from nine months to 15 months. In addition, the length of the subsidy eligibility period had been extended from December 31, 2009 to March 31, 2010.
BUT THAT'S NOT ALL. The Temporary Extension Act creates new notification requirements for employers. AHI's Complete COBRA Compliance Kit gives you expert advice on the new changes, including:
- who is required to be notified of the changes to COBRA;
- what information the new notices must include;
- how to handle qualified beneficiaries whose subsidies expired on November 30 and who dropped COBRA coverage;
- what is required if someone paid their full COBRA premium for coverage before they became eligible for the subsidy extension; and
- what changes were made to determine who is eligible for the subsidy.
But AHI's Complete COBRA Compliance Kit covers much more than just the subsidy requirments.
If you're already an expert in COBRA administration, then you don't need the Kit. But, if you're like many HR execs who have many other issues to deal with, the Kit gives you a resource you can turn to whenever you have a question concerning COBRA administration so that you don't make a mistake that can come back to haunt you. The Kit answers over 120 questions, including:
- An employee's ex-wife said we should have provided her with COBRA coverage. He never told us he was divorced. What should we do?
- If we change our current company health plan options, for better or worse, does the new coverage apply to COBRA participants as well?
- Must we provide a separate COBRA notice to every qualified beneficiary?
- Do we have to offer COBRA coverage to a terminated employee who is covered by her spouse's insurance?
The Kit also gives you tools to ease your administrative burden, including:
COBRA Subsidy Tracking Sheet — Use this Excel sheet to properly calculate and track the tax credit you are taking. COBRA Compliance Documents — All of the COBRA forms and notices you need in order to be in compliance with COBRA regulations, including:
- Notice To COBRA-Payable Entity Of Qualified Beneficiaries Eligible For COBRA Subsidy
- Opt-Out Letter For Subsidized COBRA Coverage
- Model Notice In Connection With Extended Time Periods
- Supplementary Checklist For COBRA - Subsidy Assistance Eligible Individuals
- Model General Notice Of COBRA Continuation Coverage Rights
- Model Health Care Continuation Coverage Election Notice Under USERRA
- Employer/Plan Administrator Notice To Employee Of Unavailability Of Continuation Coverage
- Notice From Employer To Employee Regarding Early Termination Of Continuation Coverage
- COBRA Notice Timing/Delivery Chart
- Checklist Of COBRA Notice Requirements
Subsidy Storage Binder — Use this binder to organize and store the mandatory paperwork you need to justify the tax credit you take so that you are prepared in the event of an audit.
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