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Dear COBRA Bob,

Is COBRA Still Important Under PPACA?

While many people wonder if the Affordable Care Act eliminates the need for COBRA, COBRA is actually a separate law that predated the ACA. ACA regulations do not modify the COBRA law in any way. Now that we’ve made it past the first Marketplace open enrollment period, the ongoing need for COBRA is even more apparent for these four reasons...

Click to discover the four reasons

The End of Preexisting Conditions

One of the key outcomes of the Affordable Care Act (ACA) is that preexisting condition exclusions will cease to exist under group health plans for plan years beginning on or after Jan. 1, 2014. While this is great news for individuals with health issues, it also has an upside for HR professionals: Effective Jan. 1, 2015, employers no longer have to issue Certificates of Creditable Coverage. The Departments of Labor, Treasury, and Health and Human Services recently issued their final regulations eliminating the requirement. However, before you rush out to deliver the great news to your employer clients, let me tell you the caveat...

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Coordinating COBRA and PPACA – Communication is the Key

Last May, the Department of Labor (DOL) provided revised notices to help employers with the rollout of the ACA’s first open enrollment which ended March 31, 2014. However, we all know that confusion is prevalent throughout any open enrollment period, and even more so during health care reform. So, it seems appropriate to revisit these notices one year after their release.

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Dear COBRA Bob,

COBRA and Marketplace Payment Collection – Timing is Everything!

"The early bird gets the worm, but the second mouse gets the cheese." - Willie Nelson

For the past 10 years I've said, "The best brokers and agents help their clients with COBRA but don't do it for them." Those of you familiar with COBRA know exactly why. Because timing is everything and now, more than ever, it's crucial that employers understand essential timelines.

That's because now, the employer may be the second mouse! Let me explain...

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Dear COBRA Bob,

How to Coordinate COBRA with Obamacare as Open Enrollment Ends

Under the Affordable Care Act (ACA), the open enrollment period for 2014 Marketplace coverage ends on March 31, 2014. If your clients offer health benefits, this date is important because of its impact on COBRA coordination. This is the first of several articles in which I will outline how to coordinate COBRA administration with the ACA after open enrollment ends on March 31.

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Dear COBRA Bob,

Are 29'ers eligible for COBRA?

If you've been paying attention to all the twists, turns, and nuances of the Affordable Care Act (ACA) rollout, you've seen and heard all of the concern around a new demographic in the workforce known as the "'29'ers."

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Dear COBRA Bob,

How Do New FSA Rules Apply in COBRA Scenarios?

On October 31, the IRS announced a loosening of the longstanding flexible spending account (FSA) use-it-or-lose-it rule. Since flexible spending accounts fall under COBRA, the next obvious question is...how will this change impact COBRA administration? As of this writing, there is no official guidance but we'll attempt to unravel the "what ifs."

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Dear COBRA Bob,
My clients are inundating me with questions about the future of COBRA. They seem to think that if coverage through the Marketplace is more affordable, COBRA will fall by the wayside. Your thoughts?

-Not Sure What to Believe in Bellevue

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Dear COBRA Bob,
My employer clients have been implementing changes around the PPACA October 1 deadline. They are asking if they need to modify their COBRA eligibility notices to include information about the exchanges. Have you heard anything about this? Which notices will need to change?

-Exhausted in Escondido

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Dear COBRA Bob,
With all the Affordable Care Act uncertainty, I've decided to focus more effort on voluntary benefit products. However, I'm not sure how COBRA works in the voluntary arena. Can you enlighten me?

-Perplexed in Peoria

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Dear COBRA Bob,
I've been hearing a lot of rumors that COBRA will be going by the wayside in 2014 once the Affordable Care Act is underway. Is this true?

-Doubtful in Durham

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Dear COBRA Bob,
Many of my employer clients have been asking if HIPAA Certificates of Creditable Coverage will still be required under health reform once preexisting conditions are no longer an issue. Your thoughts?

-Wannabe Credible in Clearwater

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Dear COBRA Bob,
I have a 35-employee group that is subject to COBRA, but not subject to the PPACA. In May, the Department of Labor (DOL) issued some guidance that included a "Notice to Employees of Exchange Coverage Options" and an "Updated Model Election Notice under COBRA." I am so confused, I can't see straight! Are these notices connected? Do both of these notices apply to this group? Who is responsible for sending them out?

-Bewildered in Boston

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Dear COBRA Bob,
I am trying to convince an employer with about 80 employees and a high deductible health plan to save money by moving to an HRA (Health Reimbursement Arrangement) instead of an HSA (Health Savings Account). However, the HR Director tells me that it is easier to administer COBRA for an HSA than it is to administer COBRA for an HRA. As an agent, I've never done COBRA administration, so can you tell me if she is right?

-Disagreeing in Dallas

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Dear COBRA Bob,
I have a client with several hundred employees. The HR Manager called me the other day and explained, "We have an employee who went out on a workers' compensation claim six months ago and it doesn't look like he's coming back to work. We have paid all of his health insurance premiums for him while he's been off work. When would his COBRA start – on the first of next month or six months ago?" I am not sure what to tell the HR Manager, can you help me?

-Not Gonna Work

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Dear COBRA Bob,
My client is an HR executive for a firm with 210 employees. Like most HR executives, she is scrambling to achieve PPACA compliance. She recently asked a COBRA question regarding "prohibition on rescission" that I was unable to answer. My client knows that the new regulation forbids retro-terminations of any kind. However, she is unsure about COBRA. What if a COBRA participant has not paid for coverage? Should the company just "eat" the premium for the COBRA participant?

-Puzzled in Pittsburgh

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Dear COBRA Bob,
While working on the employee handbook, we ran into a "conundrum" and thought we'd ask you. Prior to PPACA, when an employee went from full-time to part-time (reduction in hours), it was a COBRA-qualifying event and each plan had full-time hours set at 30, 32 or 36 hours per week, depending on the plan. Now with PPACA, the full-time equivalent (FTE) eligibility requirement for ALL plans is 30 hours per week. Here are my questions: First, is reduction in hours still a COBRA event? Second, is the new 30-hour FTE measurement applicable in all COBRA situations?

-Spring Training, Clearwater, FL

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Dear COBRA Bob,
One of my clients is an employer with 160 associates. The HR team manages COBRA in-house and it seems like they have eight to 10 people on COBRA at any given time. Over the past few years (due to the down economy, I'm guessing) many participants have gotten into the habit of paying for COBRA right at the end of their grace periods. The HR team has spent way too much time dealing with this issue. What proactive measures could they take to encourage participants to pay earlier? Should they allow COBRA participants to pay with credit cards or ACH? Any other ideas?

- Lamenting the Laggers in LA

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Dear COBRA Bob,
We are into the New Year and our W-2s are due this month. We only have 30 employees. Do the new PPACA requirements apply to us? Is there still transition relief?

I am about to tear my hair out because this is so confusing. Is my broker supposed to do this for us? The carrier? How should we report the former employees, the COBRA participants or anyone on a severance arrangement?

- Panicked about PPACA in Pittsburgh

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Dear COBRA Bob,
My client's business is merging with another company. We've spent a lot of time thinking about employee and health plan transitions, but haven't tackled COBRA issues yet. Any suggestions?

- Managing Change in Chattanooga

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Dear COBRA Bob,
Every year during the holidays, I receive countless questions from clients about the grace-period rules. If a COBRA participant's premium is due on the 1st and he has an additional 30-day grace period in which to remit, does the grace period get extended to make up for holidays?

- Confused in California

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Dear COBRA Bob,
One of my clients neglected to cancel COBRA coverage for a participant who stopped participating in the plan. Unfortunately, it took them 16 months to discover the problem and the overpayment is now at $14,384. What can they do Sincerely,

- Miserable in Massachusetts

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Dear COBRA Bob,
Open enrollment season feels a little different this year with all the health-reform hype. Do you have any advice about how I should talk to my clients about COBRA?

- Pondering in Portland

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Dear COBRA Bob,
One of my clients has a COBRA dispute involving an employee who split with her domestic partner. Are domestic partners covered by COBRA? The HR administrator says, "Yes," but I believe the answer is no. Who is right?

- Divided in Detroit

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