An Overview Of COBRA

• Background
• Purpose
• Administration
• Cost To Employers
• Penalties For Noncompliance With COBRA

Employers And Plans Covered By COBRA

• Employers And Plans Subject To COBRA
• Defining A Group Health Plan
• Maintaining A Group Health Plan

The General COBRA Notice

• The General COBRA Notice
• Consequences Of Failure To Provide The General COBRA Notice
• How To Send The General COBRA Notice
• HIPAA Notice

Covered Employees And Qualified Beneficiaries

• Who Is A Covered Employee
• Who Is A Similarly-Situated Non-COBRA Beneficiary
• Who May Be A QB
• Who May Not Be A QB
• A QB’s Rights Under COBRA
• QBs Located Outside Of The Plan's Service Area
• Repeal Of The Core Coverage Requirement

Qualified Events

• Defining A Qualified Event
• List Of Qualified Events
• What May Be A QE
• Expansion Of COBRA's Loss Of Coverage Definition
• What May Not Be QE
• Duration Of COBRA Coverage
• Expanded Coverage For Additional QEs (Multiple QEs)
• Special QE Issues: Gross Misconduct
• Special QE Issues: Disability
• Special QE Issues: Cessation Of Dependency Status
• Special QE Issues: Divorce Or Legal Separation
• Special QE Issues: Medicare And Initial QEs
• Special QE Issues: Medicare And Multiple QEs
• Determining The QE Date
• Providing More Than The Required COBRA Coverage
• COBRA Notice Rules: Reasonable Notice Procedures

QE Notices

• QE Notices
• What QE Notices Should Include
• To Whom Should QE Notices Be Sent
• When To Send A QE Notice
• How To Send A QE Notice
• Handling Coverage During The Election And Payment Period
• Responses To Provider Inquiries Concerning QBs

COBRA Issues Under The Trade Act Of 2002

• Introduction
• Second Chance COBRA Election
• Health Coverage Tax Credit

Administration And Documentation

• Coordination Of Administrative Resources
• Summary Plan Descriptions
• Keep The Envelopes, Use The Postmarks

Timelines

• The COBRA Timeline
• Understanding And Managing The COBRA Timeline
• Employer And QB Notification To The Plan Administrator
• 14-Day Notification Period
• 60-Day Election Period
• 45-Day Retroactive Premium Payment Period
• 30-Day Grace Period
• Using The Correct Procedures
• Strategies For Protecting Against Accidental Free COBRA Coverage
• Finding Out About Other Coverage

Calculating COBRA Premiums

• Determining COBRA Premiums For Insured Plans
• Determining COBRA Premiums For Self-Funded Plans
• Handling Rate Changes
• COBRA’s 12-Month Determination Period
• Determining Rates For Related QB’s Who Independently Elect COBRA
• Rates For A QB’s Newly Added Spouse or Dependent

Billing And Collection Of COBRA Premiums

• How To Bill Current QBs
• Who To Bill For COBRA Coverage
• Who Can Pay For COBRA Coverage
• What Is Timely Payment: Premium Payment Deadline
• What Is Timely Payment: Timely Payment
• What Is Timely Payment: Partial Payment
• What Is Timely Payment: Employer Subsidized / Alternative Coverage

Open Enrollments

• Who Is Entitled To Open Enrollment Rights
• Changes In Coverages During Open Enrollments
• Effect Of Plan Terms On QBs' Open Enrollment Rights
• Plan Changes And Their Effect On QBs
• Open Enrollment Changes By Active Employees And Potential QEs

USERRA

• Introduction
• Protected Individuals
• Health Care
• Interaction With COBRA
• Election Notice
• Health Care Premiums
• USERRA Does Not Extend Beyond 18 Months Of Continuation Coverage

Medicare

• Medicare Basics
• Entitlement vs. Eligibility
• Medicare And Initial QEs
• Medicare And Multiple QEs
• Medicare As An Event Terminating COBRA Coverage

COBRA's Alternative Coverage Rules

• Defining Alternative Coverage
• Using Alternative Coverage To Offset COBRA
• Consecutive Coverage Method
• Concurrent Coverage Method
• Choice Method
• Making Your Alternative Coverage Method Work
• Choosing The Correct Method

Terminating COBRA Coverage

• An Overview Of The Rules Governing Terminating COBRA Coverage
• Events Terminating COBRA Coverage
• Natural Expiration Of COBRA Continuation Period
• Termination Of COBRA Because Of Employer's Cessation Of Health Plan Sponsorship
• Termination Of COBRA For Failure To Pay Premiums
• Termination Of COBRA Because Of Other Group Health Plan Coverage Or Medicare Entitlement
• Termination Of Extended Disability COBRA Coverage Because Of Cessation Of Disabled Status
• Procedures For Terminating COBRA Coverage

Other Issues

• State Laws Health Care Continuation Rules
• COBRA And the Family And Medical Leave Act
• Conversion Coverage Rules
• Flexible Spending Accounts
• Deductibles, Limits, Split Family Units
• Penalties For Non-Compliance

Sample Forms, Notices, And Checklists

• Documentation Form
• General COBRA Notice
• QE Notice - Termination/Reduction
• QE Notice - Cessation Of Dependency
• QE Notice - Death/Divorce - L.S./Medicare
• HIPAA Request For Certificate Of Coverage
• HIPAA Certificate Of Coverage
• HIPAA Certificate Of Coverage By Categories
• Termination Of COBRA Coverage Notice
• Responsibilities Checklist
• About The Manual
• IRS Notice 98-12
• About COBRA Continuation Coverage Rights
• Notice Of Unavailability Of Coverage

COBRA ADMINISTRATION PROCEDURES

• Suggested Procedure For Sending The General COBRA Notice
• Suggested Procedure For Identifying QEs
• Suggested Procedure For Managing Cessation Of Dependency Status Issues
• Suggested Procedure For Sending QE Notices
• Suggested Procedure For Handling Coverage During The Election And Payment Period
• Suggested Procedure For Late and Partial Payments And Bounced Checks
• Suggested Procedure For Open Enrollment Changes
• Suggested Procedure For Determining Medicare Entitlement
• Suggested Alternative Coverage Procedure: Concurrent Coverage Method
• Suggested Alternative Coverage Procedure: Choice Method