Choice COBRA Administrative Guide
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1 Choice COBRA Administrave Guide The Choice COBRA Administrave Guide is designed to provide the necessary informaon to assist you in your COBRA administraon service and to help you navigate and feel comfortable with the COBRA website and COBRA Companion portal.
Transcript of Choice COBRA Administrative Guide
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Choice COBRA Administrative Guide
The Choice COBRA Administrative Guide is
designed to provide the necessary
information to assist you in your COBRA
administration service and to help you
navigate and feel comfortable with the
COBRA website and COBRA
Companion portal.
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Overview and Notifications Page 3
Required COBRA Notifications Page 4
Events that Trigger COBRA Continuation Page 5
Qualifying Event Notice Procedure Page 6-7
Qualifying Event Form Page 8
COBRA Companion System Page 9
Navigating COBRA Companion Page 10-13
COBRA Elections Page 14
Collected COBRA Premiums and Remittance Page 15
Open Enrollment and Insurance Plan Changes Page 16
Termination of COBRA Continuation Page 17
COBRA Member Services and Client Services Page 18
TABLE OF CONTENTS
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As part of our COBRA administration service, it is the responsibility of the employer to
provide timely notification to us regarding events that trigger COBRA. COBRA provisions
apply to all group health plans, dental plans and visions plans. In most instances, Flexible
Spending Accounts under Section 125 Cafeteria Plans and Section 105 Health
Reimbursement Arrangements are subject to COBRA.
There are two types of notices that must be provided, which will be distributed by our
COBRA administration team:
General Notice: the General Notice must be mailed 1st class to an employee
(and spouse, if applicable) when first covered under the group plan. This is a
brief document that outlines the employee’s rights and responsibilities with
respect to COBRA and must be provided in written form. Enrollment into only
an FSA does NOT require a general notice.
Qualifying Event (QE) Notice: the QE notice is provided to qualified
beneficiaries at the time a qualifying event occurs. The notice is a lengthy
document that outlines the continuant’s rights under COBRA to elect coverage,
explains the deadlines for election, lists the benefits available along with their
monthly premiums and provides a COBRA election form.
Additional items that must be provided to a qualified beneficiary or COBRA participant,
which will also be distributed by our COBRA administration team are:
HIPAA Certificates of Creditable Coverage (provided in the QE notice, at the
termination of COBRA or if an active employee voluntarily drops benefits)
Conversion Notice (provided 180 days prior to the end of a participants COBRA)
Termination Notice (provided upon termination of COBRA)
Open Enrollment Materials for COBRA continuants
OVERVIEW AND NOTIFICATIONS
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General Notices
The following information must be submitted in order to generate and mail a General Notice:
Employee’s Name and Address
Date of Birth
Social Security Number
Hire Date
Spouse/dependents name, address, SSN, DOB
Plan Enrollment (Medical, Dental, Vision, EAP, FSA, JRA, etc.)
Coverage levels by plan type
Benefit Coverage Start Date
Qualifying Event (QE) Notices
The following information must be submitted in order to generate and mail a QE Notice:
Employee’s Name, Address, Phone
Date of Birth
Social Security Number or Employee Number
Hire Date
Benefit Coverage Start Date
Type of Qualifying Event and date of loss of coverage
Plan Enrollment (Medical, Dental, Vision, EAP, FSA, HRA, etc.)14
Coverage levels by plan type
Spouse/dependents name, address, SSN, DOB
Severance information, if applicable
Information for both notices are submitted through the Qualifying Event Form or COBRA
Companion online portal (see Qualifying Event Notice Procedure section). It is also
important that all required information is received as each piece of information has
importance with relation to compliance for both COBRA and HIPAA regulations.
REQUIRED COBRA NOTIFICATIONS
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Events that trigger the offering of COBRA continuation are know as Qualifying Events (QE).
Depending on the type of QE, COBRA continuation may extend 18 or 36 months. There is
also an 11 month extension for COBRA participants who become disabled prior to or within
the first 60 days of COBRA coverage. The following events will trigger COBRA
continuation :
Events that trigger COBRA Continuation for up to 18 months:
Termination (voluntary or involuntary; may include ‘gross misconduct’)
Retirement
Reduction in hours worked (which result in a loss of coverage)
Events that trigger COBRA Continuation for up to 36 months:
Divorce or legal separation
Death of an employee
Dependent ceasing to be a dependent as defined by the group plan
The event must result in the qualified beneficiary losing coverage for it to be deemed a QE.
For example, an employee who goes from full time to part time status, but remains covered
under the plan as a part time employee, does not incur a QE (reduction in hours) as he/she
have not lost coverage.
Other Events:
Voluntary termination of benefits for an active employee and/or dependent is
NOT a COBRA qualifying event but does require a termination letter and a HIPAA
Certificate of Creditable Coverage. Therefore an event must be entered in our
COBRA Companion system or a Qualifying Event Form submitted.
EVENTS THAT TRIGGER COBRA CONTINUATION
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Employer’s Notice to COBRA Administrator
You must notify us within 30 days that a qualifying event has occurred. We will notify the
qualified beneficiaries of their rights under COBRA and if the person has a benefit through
Choice Strategies we will take care of the termination. All other carriers should be
notified of the termination by the employer.
The General Notice for newly covered employees or spouse will be mailed within 24-48
hours from receipt, as well as the COBRA Qualifying Event Notification if entered in COBRA
Companion. If a Qualifying Event Form is submitted the notices will go out within 5-7
business days. Please note, missing information will delay the timeframes noted.
While much of the COBRA burden falls on the employer, COBRA does allocate some
responsibilities to a covered employee or qualified beneficiary. Employees and Qualified
Beneficiaries must notify their employer, within 60 days, of the following events:
Divorce or legal separation
Death of an employee
Dependent ceasing to be a dependent as defined by the group plan
Entitlement to Medicare
To notify us of a Qualifying Event :
Log onto Choice COBRA website: www.choice-strategies.com/cobra
Click on COBRA Forms. See page 7
Click on Qualifying Event Form OR COBRA Companion. Either system can be
used to enter events. See page 7
QUALIFYING EVENT NOTICE PROCEDURE
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QUALIFYING EVENT FORM
The Qualifying Event Form is one option for entering events. It does not require a username
and password ; however, the data is maintained in a secure environment when submitted
to our office. The Qualifying Event Form has a comments section, which allows the client to
communicate any special instructions.
Click on Qualifying Event Form and enter all applicable data
You will have the option to print a copy of the document and you will immediately re-
ceive an email verification
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COBRA COMPANION
The COBRA Companion System is the other option for entering events. The system also
has reporting capabilities. Once again it is accessed through the Choice COBRA website:
www.choice-strategies.com/cobra
Click on COBRA Forms
Click on COBRA Companion System
Enter User Name and Password
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Main Dashboard:
Quick links for access to Events, Group
Information, Reports
View at a glance
COBRA queue
System messages
Contact information
Help links for how to use the portal and information
related to COBRA.
Queue Dashboard
You can view and/or edit information for individuals that you have entered into the system.
Group Information:
change passwords
view your company information
View carrier information and rates
NAVIGATING COBRA COMPANION
Click to access information
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Events: main screen to add COBRA Qualifying Events and Employee Events. See page 13 for further instructions.
Qualifying Events: screen shots to the right show the steps to submit a qualifying event for a qualified beneficiary.
Use drop down fields to select your QE. Option to select the qualified beneficiary or to enter manually.
If you selected a name from the drop down list, the Qualifier Information form will be prepopulated. If you selected ‘Not Entered’ you will need to populate the appropriate fields.
Verify information and/or enter as indicated and click ‘next’ to move through the associated screens.
Clicking ‘save’ at the end, will move the qualified beneficiary to your queue and submit for processing.
Employee Events
Submitting an employee event uses the same process as submitting a QE.
Click on the appropriate radio button for the employee event.
Select person from drop down list or manually enter.
Follow prompts, and click ‘save’ to submit.
NAVIGATING COBRA COMPANION
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Reports
Quickly find what you are looking from the reports page
Available reports include
Initial Notice
Qualifying Event
COBRA Tracking
COBRA Paid Through
COBRA Past Due
COBRA Termination
Insurance Enrollment Report
NAVIGATING COBRA COMPANION
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ENTERING EVENTS ON COBRA COMPANION
Click on ‘Events’ tab at the top of the of the main
screen
From the Events main screen, you can enter
Qualifying Events Employee Events
To enter a qualifying event
Click on the drop down box in the COBRA Qualifying Events section and select the qualifying event
Select the name of the qualified beneficiary from the drop down box. If the qualified beneficiary is not listed, select Not Entered
To enter an Employee Event such as initial notification, address change, and the like
Click on the appropriate radio button
Click ‘Go’
A screen will appear that will be prepopulated with the employee information if a name was selected.
Enter the ‘Event Date’ at the top of the page. Verify information.
Click ‘Next’ and verify information on each screen.
Click ‘Save’
If ‘Not Entered’ was selected, you will need to manually enter the information on each screen.
Click ’Next’ after each screen Click ‘Save’. COBRA beneficiary will be added to
the queue.
Qualifying event will be added to queue and uploaded at the end of each day.
Events Main Screen
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Once a Qualified Event Notification is sent to the qualified beneficiary, they may elect to
continue some or all of their benefits through COBRA. When we receive the completed
election form, we will:
Update our system with the election information and track election timelines
Send a payment coupon book
Contact the appropriate carriers to reinstate the person on COBRA continuation
Notify you of the reinstatement via email
If the qualified beneficiary returns the election form without the proper payment, we will
not contact the appropriate carriers to reinstate the person until all premiums to date are
received. We will communicate this information to the qualified beneficiary and also let
them know they have 45 days from the date of election to make the appropriate payment.
Due to the fact that QE Notices are generally not sent immediately after a QE, continuants
may experience interruptions in coverage. We make every effort to contact carriers within
3—5 business days after a completed enrollment is received to ensure minimal disruption
in service. We encourage you to send in the event as soon as you are aware of it. It is
always best to send out the QE Notice in advance of the termination date.
If the qualified beneficiary is not paid to current status but is within the grace period, they
do have the option to pay for services or prescriptions and then submit a claim form to the
insurance carrier for reimbursement.
COBRA ELECTIONS
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COBRA premiums are always due on the first day of the month for which they cover. In
addition, COBRA participants are afforded a 30 day grace period, by the IRS, in which to submit
their premiums before they are considered delinquent. We will accept premiums received in our
office postmarked up through the 30 day grace period.
Our premium payment coupons and correspondences to the participants indicate that payments
should be received by the 1st of the month to avoid service interruptions, but many participants
send payments late in the month for which they are due.
A COBRA participant who fails to make payment by the last day of the grace period will have
their COBRA coverage terminated retroactively to the first day of the period for which premiums
were due. For example, if a COBRA payment due on June 1st is not postmarked by June 30th
(end of the 30 day grace period), then COBRA coverage will be terminated retroactively to June
1st, and the COBRA payment returned. In addition, we reserve the right to cancel their coverage
as of the 1st of the month if payment is not made and subsequently reinstate their coverage if
payment is made by the 30th of the month.
In the case of insufficient funds, the participant will be notified of the NSF and given an
opportunity to make acceptable payment within a defined number of days.
Remittance of all COBRA premiums received during the month will be reimbursed back to the
employer the first week of the following month. For example, all COBRA premiums collected in
the month of July will be remitted to the employer in early August. Premiums are remitted
through direct deposit or a physical check, along with a remittance report.
We recommend that the employer pay all COBRA participant premiums to the insurance
providers when they are due to avoid service interruptions and eligibility problems. If a
continuant does make payment, a retroactive credit will be applied by the insurance provider the
month following.
COLLECTED COBRA PREMIUMS & REMITTANCE
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If an Open Enrollment period is offered to active employees, the same options must be
offered to each COBRA participant receiving continuation coverage. Open Enrollment is
the period of time in which a participant may:
Switch from one group health plan to another.
Switch to another benefit package within the same plan.
Add benefits previously declined
Add coverage of family members (coverage can be dropped anytime during the
year).
Open enrollment packets will be mailed to each COBRA participant through our service.
Benefit plan changes, new rates, additional materials, and open enrollment deadlines
should be submitted upon receipt of the information, but no less than 60 days prior to
your open enrollment period, if feasible. The communication to COBRA participants will
include
New plan rates
Election forms
Benefit summary and other information provided
We will collect Open Enrollment Election Forms from participants and notify carriers of
changes. We will also send new payment coupons to participants with rate changes.
Plan Changes
If an employer decides to change insurance carriers at any time, this information must be
communicated to our office immediately so we can notify the COBRA participants. Plan
changes or the introduction of a new plan sponsor must also be provided to COBRA
participants.
OPEN ENROLLMENT & PLAN CHANGES
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Early COBRA Continuation Termination
In instances where COBRA continuation can be terminated early, such as:
Written request for termination made by the qualified beneficiary
Late or non-payment of premium
Employer elimination of group health benefits
Qualified beneficiary becomes entitled to Medicare, after the date of COBRA
election
We will notify the insurance providers of the COBRA termination, and send the appropriate
notification letters to the COBRA participants. We will notify you of the termination
through email.
Completion of COBRA Continuation
In instances where COBRA continuants have completed the 18, 29 or 36 month
continuation period, we will notify insurance providers of the COBRA termination, and
send the appropriate notification letters to the COBRA participants and notify you through
email.
TERMINATION OF COBRA CONTINUATON
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COBRA MEMBER SERVICES
Client and Member Services:
COBRA notifications include information about Member Services and the toll-free number
to contact with questions, concerns or issues. Should a COBRA beneficiary contact you,
we ask that you direct them to call the COBRA member services department.
Member Service Hours: Monday through Friday 9:00 a.m. to 5:00 p.m.
Toll Free Number for COBRA Beneficiaries: 888-343-0133
Email: [email protected]
Fax: 401-921-3518
Choice COBRA Dedicated Support Team
Who Do You Contact? What Do You Need?
How to Reach Choice COBRA
Lori Iavarone Office Manager
* Operational Issue Resolution
* Overall Service Concerns *COBRA Companion Training, Assignment of User
Names and Passwords * Questions on EDI File
Telephone: 888-343-0133 X32 Fax: 401-921-3518
Sarah Peckham Client Service
Representative (CSR)
* Groups Beginning With A - L 1. COBRA Reinstates
2. COBRA Cancels 3. Renewal of All Plans
Telephone: 888-343-0133 X25
Fax: 401-921-3518 [email protected]
Lynn Collins Client Service
Supervisor
*Groups Beginning With M - Z 1. COBRA Reinstates
2. COBRA Cancels 3. Renewal of all Plans
4. CSR Concerns, Training, Updates
Telephone: 888-343-0133 X23
Fax: 401-921-3518 [email protected]
Regina Tibbitts Accounting Manager
* COBRA Premium Reimbursements * Premium Payment Issues
Telephone: 888-343-0133 X21 Fax: 401-921-3518
Lisa Badway
Accounts Receivable
* COBRA Premium Posting * Credit Card Payments
Telephone: 888-343-0133 X24
Fax: 401-921-3518 [email protected]
Amanda Iavarone Eligibility Specialist
*Processes new hires, additions, terminations, address changes *Eligibility Issues
Telephone: 888-343-0133 X28 Fax: 401-921-3518
Barbara Nardolillo New Account Liason
*Requests for Proposals * Installation of all New Account
* Initiates Welcome Calls to New Accounts
Telephone: 888-343-0133 X27 Fax: 401-921-3518
Claire Moody COBRA Eligibility
Processor
* Generates COBRA Qualifying Event Notices * Generates Initial COBRA Notices
Telephone: 888-343-0133 X26 Fax: 401-921-3518
Visit Our Website at: www.choice-strategies.com/cobra
