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COBRA, HIPAA, FMLA, ADA Certification And More
COBRA, HIPAA, Sec 125 Compliance Seminars
TABLE OF CONTENTS
Section One: Background And Overview
- Dramatic Changes Affecting All Group Health Plans Are Now Law
- General Overview
- Who This Affects
- Who Benefits
- Direct Costs
- Indirect Costs
- Common Fallacies And Mistaken Beliefs
Section Two: Key Terms, Definitions, Descriptions
- Timeline: Key Effective Dates
- Key HIPAA Terms And Concepts
- New HIPAA Definitions
- HIPAA’s Non-Discrimination Requirements
- Changes To COBRA Rules: Expanded Definition Of QBs
- Changes To COBRA Rules: COBRA Disability Extension
- Changes To COBRA Rules: Terminating COBRA Coverage
- Changes To COBRA Rules: Medicare Entitlement Classification
- Enforcement
Section Three: Fundamentals Of Certificates Of Coverage
Basic Rules
Special Rules
- Individual Enrollment Rules
- Dependent Enrollment Rules
- Special Rules For Dependent Coverage
- Interplay With Cafeteria Plans
About Certificates Of Coverage
- Format
- Required Information
- "Categories" Of Benefits
- Who Must Provide Certificates
- When To Provide Certificates
- Automatic Certificates: Loss Of Coverage
- Automatic Certificates: Loss Of COBRA
- Certificates "Upon Request"
Special Considerations: Plans Subject To COBRA
- HIPAA And COBRA Compliance
- HIPAA’s Effect: COBRA Admin. Process
- Handling Coverage During Election Period
- Interplay: Non-QE Losses & COBRA Events
- COBRA Cut-Off vs. HIPAA Pre-Ex Rules
- Expected Impact On COBRA Election Rates
Section Four: Requirements Through June 1, 1997
- Notice To COBRA Qualified Beneficiaries
- Coverage Tracking Requirements
- Notice To All Individuals Who Lost Group Health Coverage After October 1, 1996
- Amend Plan Documentation, Forms, & Notices
Section Five: If The Plan Is The "OLD" Plan
Tracking, Sending, Confirming Certificates
- Tracking
- Sending Certificates
- Procedures For Sending Certificates
- "Designated" Recipients
- Sending "Requested" Certificates
- Documentation Issues
- Administering Certificates
- Confirming Certificates
Section Six: If The Plan Is The "NEW" Plan
General Rules
Receiving, Evaluating, Verifying Certificates
- Receiving Certificates
- Exceptions To Pre-Ex Limitations
- Basic Steps In Evaluating
- Access vs. Coverage
- Review Process
- Calculating Periods Of Prior Creditable & Breaks In Coverage
- Standard Method
- Alternative Method
- Administrative Procedures
- Dealing With Pre-Ex Limitations Already Imposed On HIPAA’s Effective Date
- Interaction: HIPAA’s Effective Date And Existing COBRA Coverage
- Other COBRA Issues
- Verifying Certificates
- Documentation Issues
Section Seven: Unresolved And Unclear Issues
- What is a "Plan"?
- FMLA and HIPAA
- Acquisition Issues
- Timing of sending Certificates of Coverage outside of the COBRA time frames; how soon is "reasonable"?
- What if I simply cannot find the information I need to complete a Certificate of Coverage or send out the safe harbor notice in lieu of Certificates of Coverage?
- How are "actively at work" rules treated under the new non-discrimination requirements in ERISA?
- What if I just stamp every outgoing Certificate of Coverage to show 18 months for every individual?
- What if I want to limit claims by excluding people through waiting periods. Can I do that? Can I simply exclude all late enrollees (instead of imposing an 18 month limitation period)?
Section Eight: Sample Forms & Notices
- Safe Harbor Notice To Be Issued By June 1, 1997
- Model Certificate Of Coverage
- Model Certificate Of Coverage For Use In Determining "Categories" Of Benefits
About The Guide To Certificates Of Coverage
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