COBRA ADMINISTRATION SERVICES

Transcription

COBRA ADMINISTRATION SERVICES
Client Guide
JULY 2012
This Client Guide contains a summary of COBRA Continuation Coverage and is not intended to provide legal or
tax advice. Please consult with your legal or tax advisor for specific legal and/or tax advice with respect to your
obligations under COBRA.
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FOR
AHA CLIENT •
USEINNOVATION
ONLY.
KNOWLEDGE
®
Administrators,
Inc. 2012
•© AmeriHealth
PERFORMANCE
• VALUE
TABLE OF CONTENTS
Section 1: Welcome. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
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New Client Set-up Checklist
Welcome Letter
AmeriHealth Administrators COBRA Contact Information
Section 2: COBRA Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
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What is COBRA?
Who It Affects
Non-Compliance Penalties
Qualified Beneficiaries
Qualifying Events
COBRA Extension
Timing and Termination of COBRA Benefits
Section 3: Establishing COBRA Administration Services. . . . . . . . . . . . . . . . . . . . 10
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New Client Set Up
QB Election
Section 4: Additional Billing Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
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Severance Agreements
Mid-Year Premium Increases
Plan Changes
Section 5: What to Do When a Plan Member has a Qualifying Event (QE) . . . 13
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COBRA Notification Procedures
Notices
Obligations for the Employer / AmeriHealth Administrators / COBRA Participant
COBRA Premium Payments
Paying Monthly Premiums
Section 6: Using AmeriHealth Administrators Online COBRA Tools. . . . . . . . . . . 18
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Entering and viewing COBRA Data Online
Qualifying Beneficiary Add Wizard
Reporting Engine: Existing Templates and Creating Ad-Hoc Reports
Qualifying Beneficiary Access
Section 7: Monthly Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
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COBRA Administration Monthly Invoice
COBRA Administration Standard Reporting
Monthly Activity Summary / Voucher Report
Primary Qualified Beneficiaries (PQB) Listing
Notification Letter Issued Report
Appendix: Sample Forms and Letters
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FOR AHA CLIENT USE ONLY.
© AmeriHealth Administrators, Inc. 2012
1
WELCOME
NEW CLIENT SET-UP CHECKLIST
To ensure your group’s set-up process with AmeriHealth Administrators (AHA) proceeds smoothly, we’ve
prepared the following simple checklist for your benefit:
__ Review, complete, sign and return the Administrative Services Acknowledgement and Authorization or COBRA Administrative Services & Fees schedule to AmeriHealth Administrators. A copy of
the signed agreement will be returned to you.
__ Complete and sign the HIPAA Group Health Plan Designated Contact Form providing both your
group’s main contact and primary finance contact for the account (if different), and return to
AmeriHealth Administrators.
__ Complete information on COBRA/Retiree New Client Implementation Form and Rate Sheet,
including the contact information for previous COBRA administrator and any outside carriers (if
applicable). If yours is a self-funded account, you must include all COBRA-equivalent rates.
__ Confirm the effective date for the AHA administration takeover (date is indicated on the Administrative Services Acknowledgement and Authorization or COBRA Administrative Services & Fees
schedule).
__ Compile information regarding existing COBRA participants on the Required Data for Existing
Qualified Beneficiaries Enrolled/Pending form and email back to AHA so we can enter these
participants into our system. Each existing primary participant will receive a welcome letter and
set of payment coupons from us.
__ Send a letter to your existing COBRA participants (pending and enrolled) letting them know that
AHA will be their new COBRA administrator and the effective date. Our address for future payments should also be included. (Contact your representative if you would like us to provide you
with a sample letter.)
Be sure to call your account representative if you have any questions.
We will also be in contact with you to complete these items and the overall transition.
Thank you and welcome to AHA!
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WELCOME
Dear COBRA Administration Client:
We are pleased to provide a copy of our COBRA Administration Services Client Guide to you as a new
AmeriHealth Administrators COBRA (the Consolidated Omnibus Budget Reconciliation Act of 1986) and
billing administration client. We pride ourselves in providing quality service and in treating all customers
as valued customers.
By choosing AmeriHealth Administrators, your administration of COBRA will be simple. We take care of
the communication, documentation, and record-keeping processes to help keep you in compliance,
making the complicated task of COBRA administration as simple as possible.
This guide explains the compliance systems and procedures designed to help make the complicated
task of COBRA administration as simple as possible. You will find samples of the monthly reports and
administrative procedures as well as other important information related to the COBRA processes.
Please call your AmeriHealth Administrators representative with any questions or concerns about
COBRA.
Respectfully,
AmeriHealth Administrators
AMERIHEALTH ADMINISTRATORS CONTACT INFORMATION
AHA COBRA CUSTOMER SERVICE
Members: Toll-free Customer Service number: 888-547-5090
Email: [email protected]
Hours of operation: Monday through Friday, 9am – 5pm ET
PARTICIPANT PREMIUMS PAYMENT ADDRESS
PO Box 820091
Philadelphia, PA 19182-0091
AHA ACCOUNTING DEPARTMENT
Bryan Baker, Billing Analyst
Phone: 215-830-2558
ALL OTHER CORRESPONDENCE
PO Box 990
Horsham, PA 19044-0990
ELIGIBILITY AND CLAIMS QUESTIONS
Participants must contact the customer service phone number provided on their ID card.
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2
COBRA OVERVIEW
WHAT IS COBRA?
The Consolidated Omnibus Budget Reconciliation Act (COBRA), signed into law in 1986, requires most
employers who sponsor group health plans to offer their employees and their eligible dependents
continuation coverage at group rates. Title 10 of COBRA amends the Employee Retirement Income
Security Act (ERISA), the Internal Revenue Code, and the Public Health Service Act for purposes of
health plan coverage.
Employers offering group health plans have a legal obligation to notify their employees of the right
to continue coverage if a “qualifying event” under COBRA occurs. The Plan must provide covered
employees and their eligible dependents with certain notices explaining their COBRA rights. They must
also have rules for how COBRA continuation coverage is offered, how qualified beneficiaries (QBs) may
elect continuation coverage, and when or how it can be terminated.
WHO DOES COBRA AFFECT?
COBRA requires that most employers who sponsor group health plans offer qualified beneficiaries (for
example, employees and their eligible dependent spouse and children) the opportunity to continue
coverage at group rates in circumstances in which group coverage would normally end. More
specifically, that means group health plans sponsored by an employer who employs 201 or more
employees (including part-time workers) on 50 percent or more of the employer’s working days during
the preceding calendar year. This includes corporations, partnerships, tax-exempt organizations, and
state and local governments, although plans sponsored by the federal government and many religious
plans are exempt from COBRA.
WHAT GROUP HEALTH PLANS ARE SUBJECT TO COBRA?
Any group health plan that is maintained or contributed to by an employer or union-sponsored plan to
provide any type of health care benefit to employees, former employees, or the eligible dependents of
such employees or former employees are subject to COBRA. That includes:
•
traditional indemnity plans
•
HMOs and PPOs
•
specialty plans such as dental, vision, and prescription drug plans
•
health care Flexible Spending Accounts (which meet certain requirements)
Life insurance or other death benefits are not considered medical benefits and are not subject to
COBRA. In addition, short and long term disability insurance are not considered subject to COBRA
provided the insurance constitutes income replacement.
DO EMPLOYERS HAVE TO PAY ANY PORTION OF THE COBRA PREMIUM?
No, there is no requirement for an employer contribution to COBRA coverage. The entire amount of the
insurance premium, plus a 2% administrative fee, may be charged to the qualified beneficiary.
ARE THERE FINES OR PENALTIES FOR NON-COMPLIANCE?
Yes, and they can be significant. The IRS places an excise tax on the employer of $100 or more per
occurence per day for non-compliance of COBRA regulations. The Department of Labor can also
penalize an employer up to $110 per day per beneficiary for non-compliance.
1. Employers must count all employees regardless of whether they have insurance coverage. In other words, employers must include full-time and part-time employees, as well as seasonal and those working in foreign countries,
when determining if they have 20 or more employees.
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COBRA OVERVIEW
QUALIFIED BENEFICIARIES
The decision to continue group health coverage may be made by the employee only. An individual
eligible for COBRA is known as a Qualified Beneficiary (QB). A QB is an individual who was covered by a
group health plan on the day before the coverage is lost due to a qualifying event. The QB is responsible
for paying the COBRA premium. Qualified beneficiaries can include some or all of the following:
•
an employee
•
an employee’s spouse (and in certain cases, former spouse)
•
the employee’s dependent children
•
dependent children born to (or adopted by) the employee while covered under COBRA
In other words, a terminating employee covering his/her eligible dependents under the group plan
on the day coverage is lost may elect to continue coverage for himself and all eligible dependents,
himself only, his spouse only, his dependent child(ren), or in some other combination. For example,
a spouse who will lose coverage may choose to elect COBRA continuation coverage even if the
terminating employee elects to waive coverage for himself/herself.
REQUIREMENTS FOR PLAN ADMINISTRATOR
COBRA regulations place the following requirements on you as the Plan Administrator:
•
Coverage must be identical to the coverage provided to similarly situated non-COBRA
beneficiaries under the group health plan. Any rate or other plan change you offer to your
regular employee population (usually during your annual open enrollment) must also be
extended to QBs;
•
Your actions must comply with COBRA laws/regulations.
WHAT IS A QUALIFYING EVENT (QE)?
Events that trigger the offering of COBRA are known as Qualifying Events (QE). There are several types
of qualifying events that would make employees, their spouses and dependent children eligible for
COBRA continuation benefits.
•
Voluntary or involuntary termination of employment2 for any reason other than “gross misconduct”;
•
Reduction in hours worked3 which result in the loss of health coverage;
•
Entitlement to Medicare4 benefits;
•
Qualifying events for a covered employee’s spouse or dependent children are:
•
death of the employee
•
termination of the employee’s employment (except for gross misconduct)
•
reduction in employee’s employment hours, voluntarily or involuntarily
•
divorce or legal separation
•
employee becomes entitled to Medicare; and
•
Dependent children may also become eligible for COBRA due to reaching the maximum
dependent age of 26 (up to 30 in some states).
Depending on the type of QE5, COBRA continuation period may be18, 29, or 36 months.
2. A member’s voluntary disenrollment from the Plan is not a QE.
3. An employee who goes from full time to part time status, but remains covered under the group health plan as a
part time employee, does not incur a Qualifying Event (reduction in hours) as he/she has not lost coverage.
4 . Medicare entitlement is not a 36-month qualifying event or secondary qualifying event with respect to the employer’s spouse and children unless the employee’s Medicare entitlement causes the family members to lose health
coverage under the active group health plan in the absence of COBRA coverage.
5 . Coverage for employees who are retiring can be processed as QEs as well
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COBRA OVERVIEW
QUALIFIED
BENEFICIARIES
ELIGIBLE PERIOD
Employee, Spouse,
Dependent Child
18 months
Layoff or reduction of hours
Employee, Spouse,
Dependent Child
18 months
Death of covered employee/retiree
Spouse,
Dependent Child
36 months
Employee’s resignation
Employee, Spouse,
Dependent Child
18 months
Employee/retiree Medicare entitlement
Spouse,
Dependent Child
36 months4
Divorce/legal separation
Spouse,
Dependent Child
36 months
Child’s dependent status changes
Dependent Child
36 months
QUALIFYING EVENT
Employee’s involuntary termination of employment
(except due to gross misconduct)
Disability/extension (as determined by Social Security
Administration) on the date of the qualifying event or
within 60 days after COBRA coverage begins
Employee’s Retirement5
Employee, Spouse,
Dependent Child
18 or 29 months (see
DISABILITY EXTENSION
below for more
information)
Employee, Spouse,
Dependent Child
18 months
DISABILITY EXTENSION
An 11-month extension of COBRA continuation coverage may be available if any Qualified
Beneficiaries are disabled, and if the following criteria are met:
•
The Social Security Administration (SSA) must determine that the Qualified Beneficiary was
disabled prior to or within the first 60 days of continuation coverage; and,
•
The QB must notify the plan administrator of that fact within 60 days of the SSA’s determination;
and before the end of the first 18 months of continuation coverage.
All of the Qualified Beneficiaries who elect continuation coverage will be entitled to the 11-month
disability extension if one of them qualifies. If the QB is determined by SSA to no longer be disabled,
notify the plan administrator of that fact within 30 days of SSA’s determination.
If the individual entitled to the disability extension has non-disabled family members who are entitled to
COBRA continuation coverage, those non-disabled family members are also entitled to the 11-month
disability extension to a maximum of 29 months.
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COBRA OVERVIEW
WHAT HAPPENS IN THE CASE OF A SECOND QUALIFYING EVENT?
An 18-month extension of COBRA continuation coverage may be available to spouses and dependent
children who elect continuation coverage if an eligible Second Qualifying event occurs during the first
18-months of continuation coverage. The maximum amount of continuation coverage available when
an eligible Second Qualifying event occurs is 36 months from the original Qualifying Event. Second
Qualifying Events include:
•
the death of a covered employee;
•
divorce or legal separation from the covered employee;
•
a dependent child’s ceasing to be eligible for coverage as a dependent under the group health
plan.
WHEN COBRA COVERAGE CAN BE TERMINATED
The Employer may terminate COBRA coverage if any of the following occurs:
•
60-DAY ELECTION PERIOD: Qualified Beneficiaries are provided at least 60 days notice (from the
date of the Qualifying Event Notice or the loss of coverage, whichever is later) to decide if they
want to elect COBRA continuation coverage. If an election form is not received within the 60day election period, the employer is not required to enroll the employee under COBRA. Group
health plans may choose to offer an election period longer than 60 days; however, before
extending the election period beyond the statutory minimum, an employer should seek approval
from their insurance carrier(s).
•
45-DAY ENROLLMENT PREMIUM PAYMENT: Qualified Beneficiaries who timely elect COBRA
continuation coverage within the 60 days are not required to remit payment for an additional 45
days from the date the enrollment form is signed. If the initial premium payment is not received
within that 45-day period, the employer may terminate COBRA continuation coverage.
•
30-DAY GRACE PERIOD FOR PREMIUM PAYMENTS: Upon timely receipt of both a completed
enrollment form and the initial premium, a Qualified Beneficiary is considered enrolled and
must be provided a 30-day grace period each month for monthly premium payments. In the
event the monthly premium is not received within the 30-day grace period, the employer may
terminate coverage.
•
18-, 29-, or 36-MONTH COBRA ELIGIBILITY PERIOD: Employers may terminate coverage at the end
of the 18-, 29- or 36-month COBRA eligibility period.
Finally, should an employer no longer provide any health plan coverage for all active employees,
they may terminate COBRA continuation coverage also, provided there is no continued coverage
available through any parent or subsidiary company.
COBRA CONTINUATION COVERAGE CAN REMAIN IN EFFECT UNTIL
•
The end of the 18-, 29-, or 36-month COBRA continuation coverage period
•
The employer no longer provides any group health plan
•
The qualified beneficiary fails to timely pay a premium
•
The qualified beneficiary becomes entitled to Medicare (unless he or she became entitled to
Medicare prior to the qualifying event)
•
The qualified beneficiary becomes covered by another group health plan6
•
For a divorced or separated spouse — he or she remarries and enrolls in the new spouse’s plan7
6,7. If the beneficiary’s new group health plan limits or excludes benefits for pre-existing conditions, that plan must
credit the beneficiary’s period of continuous coverage toward the plan’s pre-existing condition waiting period.
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COBRA OVERVIEW
If a qualified spouse or dependent child elects to continue coverage and incurs additional qualifying
events while his or her COBRA coverage is in effect, the COBRA continuation coverage is limited to a
maximum of 36 months, regardless of the number of qualifying events.
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ESTABLISHING COBRA ADMIN SERVICES
FOR QUALIFIED BENEFICIARIES
ESTABLISHING COBRA ADMINISTRATION SERVICES FOR QUALIFIED
BENEFICIARIES (QBs)
AmeriHealth Administrators is hands-on, overseeing many of the procedures to help keep your plan in
compliance.
Once you contract with AmeriHealth Administrators to administer COBRA coverage for your group
health plan, there are certain procedures and forms which need to be completed to ensure that
COBRA coverage is implemented in the required timeframe. Your AmeriHealth Administrators
representative will let you know what information is needed and will provide you with the forms to be
completed and returned either electronically or by paper.
NEW CLIENT SET UP
Implementation will begin once AmeriHealth Administrators receives the completed required forms.
•
Acknowledgement and Authorization or COBRA Administrative Services & Fees Schedule
•
COBRA/Retiree New Client Implementation Form
•
Required Data for Existing Qualified Beneficiaries (QBs) Enrolled/Pending
The COBRA/Retiree New Client Implementation Form concisely captures the information needed
to set up services for new COBRA administration clients. If you prefer, you may use the AHA COBRA
Enrollment Spreadsheet or follow the directions found on the “AmeriHealth Administrators COBRA
Enrollment Data Requirements” sheet to be sure that all of the information requested is provided
in the proper timeframe, 45–60 days prior to the effective date. Your AmeriHealth Administrators
representative can provide you with a “Completing the AHA COBRA/Retiree New Client
Implementation Form” direction sheet or help guide you in properly completing the form.
QB ELECTION OF COBRA
Once a notification is sent to the Qualified Beneficiary, they may elect to continue some or all of their
benefits through COBRA. In order to elect benefits, the QB must complete the form included with the
QE Notification and return it within 60 days from the later of the termination date or the date of the
COBRA notification. The QB has the option to take an additional 45 days to pay, but when payment
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ESTABLISHING COBRA ADMIN SERVICES
FOR QUALIFIED BENEFICIARIES
is sent, it must include all premiums due from the date of the Qualifying Event through the end of the
current premium month. At this point, AmeriHealth Administrators will update the QB in our system and
contact the appropriate carrier(s) on your behalf to enroll under COBRA continuation coverage. If the
QB returns the enrollment form with less than the total payment due or none at all, AHA will respond
that we have received the enrollment form but COBRA will not commence unless payment in full is
received within 45 days.
Due to the fact that there may be some length of time between when a Qualifying Event occurs, when
AmeriHealth Administrators is informed, and then AHA processes and sends rhe QE Notice, it is possible
that Qualified Beneficiaries may experience interruptions in coverage. AHA does make every effort to
contact your insurance carrier within 7–10 business days after a completed election form is received in
order to minimize this disruption in coverage.
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ADDITIONAL BILLING CONSIDERATIONS
In addition to providing AHA with information regarding QBs for the General and Qualified Event
Notices, the employer should also keep AHA informed of the following:
SEVERANCE AGREEMENTS
In the event of a severance agreement that includes COBRA continuation coverage health benefits,
the QE information should be provided to AHA in exactly the same way as with any other situation.
Please note that the Qualifying Event date will still be the actual date that the QE occurred (e.g. date
of termination). It is recommended that the employer terminate the participant with the carriers just as
they would for any other QB.
AmeriHealth Administrators will notify the participant in the same manner so that an enrollment form
must still be filled out by the QB in order for COBRA, and the severance, to begin.
It is important, however, that if a severance agreement does include COBRA continuation coverage ,
the employer must communicate the relevant terms of the severance agreement (including benefits
affected, amount and duration of severance) to AHA in writing. Once the participant elects COBRA,
AHA will forward the enrollment form to the insurance company to reinstate the participant back onto
the group health plan and their premium payments will be reduced according to the terms of the
severance agreement. (Sample severance letter language can be found in the Appendix.)
MID-YEAR PREMIUM INCREASES
Once a Qualified Beneficiary elects COBRA continuation coverage, he or she can be required to
pay premium increases under certain circumstances. In the event a new “plan year” starts and the
applicable premium increases for active employees, the new rate can be charged by the employer to
the Qualified Beneficiary.
It is the responsibility of the employer to communicate any rate changes to AmeriHealth Administrators.
This will allow AHA to generate new premium payment slips for all affected COBRA participants.
These rates should be communicated at least 30 days prior to the change. Under COBRA regulations,
Qualified Beneficiaries may not be required to pay rate increases more than one time in a 12-month
period.
PLAN CHANGES
If an employer decides to change insurance carriers at any time, this information must be
communicated immediately to AmeriHealth Administrators. It is also the responsibility of the employer
to send open enrollment information to all eligible COBRA continuation participants in the event of a
group health plan change or the introduction of a new plan sponsor.
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WHAT TO DO WHEN A PLAN MEMBER HAS A
QUALIFYING EVENT
COBRA NOTIFICATION PROCEDURES
EVENT
Qualifying Event (QE) occurs
Qualifying Event Notice sent to qualified
beneficiary (QB)
COBRA Election period
AmeriHealth Administrators mails premium
billing statement and payment slips
Premiums collected from QB
Activity reports provided to employer
End of COBRA Eligibility Notice sent
TIMELINE
AmeriHealth Administrators must be notified
within 30 days of QE
AmeriHealth Administrators provides election
notice to QB within 14 days of QE notification
Once notified, QB has 60 days to elect or
waive COBRA continuation coverage
Upon receipt of QB election of COBRA
Monthly
90 days prior to the end of qualified
beneficiary’s COBRA eligibility period
NOTICES
The Group Health Plan is responsible for sending all notifications to qualified beneficiaries. There are two
types of NOTICES that must be provided — the Department of Labor General Notice and the notice
upon the occurrence of a qualifying event.
COBRA General Notice1
COBRA provides that the “Group Health Plan”— the employer — is responsible for providing a notice
of COBRA rights. The General Notice, often overlooked, must be given to an employee (and spouse if
applicable) when first covered under the group health plan. It should be provided either at the time of
hire or within 90 days of when an employee becomes eligible for the employer’s group health benefits.
This notice is a brief document which outlines the employee’s future rights and obligations should they
lose coverage due to a qualifying event, and must be provided in written form.
1. AmeriHealth Administrators can send these notices if requested (additional fees apply). Via First Class mail, AHA
can address and send* the General Notice to the employee “and eligible dependents” which means that the
spouse or other covered dependents have the right to open that piece of mail. AHA requires the following information in order to generate and mail a General Notice:
• Employee’s Name & Address
• Date of Birth
• Social Security Number or Employee Number
• Hire Date
• Benefit Coverage Start Date
This information may be provided to AHA via a spreadsheet, email, or via a template provided by AHA.
* NOTE: Simply handing the General Notice to an employee who also has covered dependents does not fulfill the
employer’s obligation because it does not ensure that the dependents will have an opportunity to read the document.
Page 13
QUALIFYING EVENT
The Qualifying Event (QE) Notice
COBRA provides that the plan administrator/employer must give written notice of COBRA rights
a second time — at the time a qualifying event occurs. The Qualifying Event Notice is a lengthy
document which outlines the QB’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
enrollment form.
The Department of Labor takes the position that the Plan Administrator (employer) is responsible for
providing the second notice, and liable for failure to do so, even in the event the Plan Administrator
delegates the responsibility to another person or entity.
When an employee experiences a qualifying event, notify both your applicable insurance carrier
and our COBRA unit electronically within 45 days of the QE. Inform AmeriHealth Administrators using
the Required Data for Existing Qualified Beneficiaries Enrolled/Pending, AHA COBRA Enrollment
Spreadsheet, COBRA Information Sheet or other method agreed upon with your representative.
Please be sure to include all required QE information as noted on the “AmeriHealth Administrators
COBRA Enrollment Data Requirements” sheet. Each piece of information has a particular importance
with relation to compliance of both COBRA and HIPAA regulations. AHA reserves the right to return
data sheets not completed in their entirety, which may delay the process of notifying the qualified
beneficiary.
EMPLOYER OBLIGATIONS
The employee and his/her eligible dependents must be notified of their rights under COBRA within 45
days after the qualifying event.
Using the online COBRA tools (see Section 6), the Employer must also let AmeriHealth Administrators
COBRA department know:
•
if participants experience a qualifying event (within 30 days of the QE);
•
if you receive word of some COBRA-qualifying activity (divorce, etc.) that requires a response.
Unless you have separately contracted for AmeriHealth Administrators to provide the service, it is the
Employer’s obligation to send the General Notice of COBRA Rights (Department of Labor notification)
to all of your employees and their dependents within the first 90 days of coverage.
AMERIHEALTH ADMINISTRATORS OBLIGATIONS
Our COBRA department will contact, inform, bill, collect, and respond to all inquiries from Qualified
Beneficiaries and COBRA participants.
•
The Qualified Beneficiary data received from the Employer is loaded into the COBRA system.
•
The election notice is created and mailed to the member within 14 days. AmeriHealth
Administrators maintains proof that it was mailed. NOTE: once a qualifying event occurs,
employees and/or their dependents must be provided a Qualifying Event Notice to the last
known address containing required information about premiums, due dates, how long coverage
may last, when coverage may be terminated, etc.
Page 14
•
Monitor 60-day election period.
•
Answer all participant questions regarding completion of the election form and the election period.
•
A premium billing invoice with payment slips is mailed to the member.
•
Collect premiums each month from the participants.
•
Monitor 45-day period for initial payment and subsequent 30-day grace period for premium
QUALIFYING EVENT
payments. Send cancellation notices to members who do not pay the billed monthly premium
amount within the grace period.
•
Disburse collected premiums to appropriate parties, along with monthly reporting package
(detail of monies collected for participants). Qualified Beneficiaries premium payments are
posted to the system within 2–3 business days.
•
AmeriHealth Administrators will send a letter to Qualified Beneficiaries 90 days prior to the end of
their COBRA eligibility period.
•
Send monthly reports to Employer noting member elections, premium and overpayments
received, active listings, and coverages cancelled.
•
Provide ongoing customer service to Qualified Beneficiaries and employers.
•
Notify Qualified Beneficiaries of premium shortages/overages.
•
Notify Qualified Beneficiaries of termination of COBRA continuation coverage due to nonpayment of premium, voluntary withdrawal, end of eligibility, etc. (Notice of Termination of
Continuation Coverage).
•
Notify participant if COBRA continuation coverage has been denied (Notice of Unavailability of
Continuation Coverage).
•
Monitor Medicare Entitlement and terminate coverage, if applicable.
•
Provide requested printouts to participants upon request, such as payment history reports or
copies of notices.
•
Provide rate change notice and new invoices to Qualified Beneficiaries .
•
Process change in status requests (family to single coverage, plan changes, address changes, etc.).
•
Conversion Notice — must be given within last 180 days of COBRA coverage. This is provided by
AHA at 90 days prior to the end of a participant’s COBRA period.
•
Termination Notice — must be provided to Qualified Beneficiaries upon termination of COBRA.
PARTICIPANT OBLIGATIONS
As part of the services we provide to our employers, we ask that all QB inquiries relating to COBRA
be referred directly to AmeriHealth Administrators. If a Qualified Beneficiary decides to enroll under
COBRA, they will be responsible for forwarding all correspondence and payments directly to AHA.
Note: It is the responsibility of the COBRA participant to notify both the insurance carrier and AHA
directly of their addition of any newborn child, adoption, or change of address.
Covered employees and qualified beneficiaries are responsible for:
•
timely election of COBRA continuation coverage — sending notice of COBRA election to
•
timely payment2 of premiums (in full) — mailing monthly premium coupon and payment to
•
Participants must notify3 AmeriHealth Administrators within 60 days of the following of
circumstances that could cause cancellation of coverage:
•
divorce
•
legal separation
•
dependent ceasing to be a dependent
•
change of address.
2. Any premium payments received after the 30-day grace period will be returned and COBRA coverage will be terminated. In the case of insufficient funds (NSF), the continuant will be notified of the NSF, assessed a fee, and given
an opportunity to make acceptable payment within a defined number of days.
3. The QB’s notice does not have to be in writing.
Page 15
QUALIFYING EVENT
COBRA PREMIUM PAYMENTS
Calculating the COBRA Premium
COBRA does not require employers to pay for continuation coverage. Employers are permitted to
charge employees 100% of the cost of the group health plan plus an additional 2% (for a total of 102%
of the plan premium).
In the event that a COBRA participant qualifies for a disability extension (additional 11 months), the IRS
allows for the insurance carrier to charge a maximum of 150% of the premium during the 11 months of
the extension.
Late Premium Payments
The initial premium payment must be made within 45 days of the date of COBRA election. The
employer or plan administrator must give a 30 day grace period from the monthly due date for
subsequent premium payments. AmeriHealth Administrators will automatically terminate any Qualified
Beneficiary whose payment is postmarked after 30 days of the due date.
Effect of Nonpayment of Premium
A COBRA Qualified Beneficiary who fails to make payment by the last day of the grace period
will cause COBRA coverage to be 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 may be terminated retroactively to
June 1st.
It is recommended that employers and plan administrators clearly indicate that a failure to pay
premiums in a timely manner will result in a loss of coverage retroactive to the date through which
premiums were last paid.
PAYING MONTHLY PREMIUMS
The initial mailing sent to employees who elect COBRA coverage include preprinted monthly payment
slips which the participant will need to return with his or her monthly premium payment.
It should be noted that our correspondence to the participants indicates that payments should
be received4 by the 1st of the month to avoid coverage interruptions. However, due to the 30-day
mandatory grace period extended by the Internal Revenue Service, many participants send payments
late in the month for which they are due. Due to this fact, AHA cannot guarantee that coverage will
not be interrupted due to late payments.
COBRA premiums are always due on the first day of the month for which they cover. In addition,
4. There are no statutory or regulatory guidelines under COBRA indicating who may or may not pay for COBRA premiums. AmeriHealth Administrators can accept premium payments from a third party. Plan documents and COBRA
notices should clearly state what information should accompany a premium payment made by a third party. For
example, the continuant’s name and social security number should be written on the check stub of a third party
payer in order to avoid confusion.
Page 16
QUALIFYING EVENT
COBRA continuants are permitted a 30-day grace period in which to post their premiums before they
are considered delinquent.
To avoid timing-based service interruptions, many employers choose to pay all COBRA participant
premiums to the insurance providers when they are due and then take a credit retroactively if a
qualified beneficiary has not made a payment. In other words, if the employer pays their June premium
on or about June 1st, the COBRA premiums for the month of June from AmeriHealth Administrators
won’t be received until early July. To avoid member coverage interruptions and eligibility problems,
employers pay the full June premiums and then take a credit for any participants who did not pay for
June on the July bill.
AmeriHealth Administrators will accept COBRA premiums received in our office postmarked up through
the 30-day grace period.
Page 17
6
USING AMERIHEALTH ADMINISTRATORS
ONLINE COBRA TOOLS
ENTERING AND VIEWING COBRA DATA ONLINE
Once your AmeriHealth Administrators COBRA administration services account has been set up, you
will have access to online tools where you can add or view Qualified Beneficiaries or print reports
related to your group’s covered COBRA continuants. You should use your online COBRA tools to notify
AmeriHealth Administrators of all new QBs.
Access your COBRA tools through the eligibility maintenance portion of your AmeriHealth
Administrators web portal.
HOME SCREEN
This is a example of how your online
AmeriHealth Administrators COBRA
tools home screen may look.
QBs and Employees section:
• Add a new QB who has
experienced a QE
• View all enrolled/pending/
terminated QBs
• Add a new employee to
receive a DOL General Notice
(additional fees may apply)
• View all employees who have
been sent a DOL General
Notice (if applicable)
Reports section:
• Run existing reports
• Build and run custom ad-hoc
reports
• View reports previously created
and emailed
If you have any questions about
these tools or if you need access
to your AmeriHealth Administrators
web portal, please contact your
administration representative.
Page 18
ONLINE COBRA TOOLS
QUALIFYING BENEFICIARY (QB) ADD WIZARD
Follow the simple 8-step Add Wizard
to enter data for new QBs. Roll your
mouse over the blue
icons for
additional helpful information.
Client/Employer Selection
screen: Confirm that your
company name appears in the
Client dropdown box and click
Yes or No for each of the special
situations listed, such as special
severance wording or whether
the QB needs to be notified
that they were denied COBRA
continuation coverage.
Event Information screen:
Complete information regarding
the Qualifying Event, selecting
from dropdown menus or
entering dates requested.
QB Group Information screen:
Provide a Group name (a
QB Group is a collection of
associated participants, most
often a family).
QB Information screen: Add
the identification and contact
data for each of the QB group’s
members — name, SSN, DOB,
address, phone number, etc.
Dependent screen: Add the
identification and contact data
for any COBRA-eligible QB
dependents.
Page 19
ONLINE COBRA TOOLS
QUALIFYING BENEFICIARY (QB) ADD WIZARD (continued)
Benefit Plan Assignment Selection
screen: Select your QB’s COBRA
benefit(s) assignment from the
dropdown list of your group’s
Benefit Plans. Fill in the dates
that the QB is eligible for COBRA,
whether there’s any waiting
period before coverage begins
(such as part of a severance
package), and when premium
billing should begin. Note the Tier
level for coverage (whether solely
for the individual or including
spouse and/or children), and
any subsidy information (if
applicable).
Prior Activity screen: This screen
should be left blank (answer
“no” to all questions) unless the
QB already has had COBRA
activity (eligibility notice has
been mailed, enrollment letter
has been received, enrolled QB is
already making payments, etc.).
Review and Save: You have a
chance to review all information
entered. If any corrections are
needed, click on the Wizard Step
in the right-hand menu to go
back to the relevant section.
If information is complete and
correct, select “Save and
Continue.”
Page 20
ONLINE COBRA TOOLS
REPORTING ENGINE
The AmeriHealth Administrators online COBRA tools include a robust reporting engine. Several existing templates
give you easy access to run and view reports on qualified beneficiaries, your benefit plans, premiums and tracking
of COBRA notifications. Plus, an Ad-Hoc Report Wizard walks you through selecting fields and creating reports with
specific fields and filters customized for your organization’s needs.
INCLUDED REPORT TEMPLATES
Premiums Reports
QB Reports
QB Balance Report
•
Administrative Fee Collected and Credited
•
QB Detail
•
ARRA Audit Report
•
QB Enrolled Premiums Listing
•
ARRA Eligible Reduced Hours
•
QB Payment
•
ARRA IRS Report
•
QB Status History
•
Disbursements including Non-Cash Payments
•
QB Termination
•
Electronic Payments
•
QB Termination by System Date
•
Premium Receipt
Young Adults potentially Affected by PPACA
•
Premium Receipt with Payment
•
Premium Reconciliation
•
Premium Reduction Summary Report
•
Premium Reduction Summary by Payments
•
Reconciliation by Payments (Voucher Report)
•
Reconciliation by Plan
•
•
Benefit Plan Reports
•
Benefit Plan Information Report
•
Benefit Plan Listing
Client/Employer Reports
•
Active QB Listing
•
Reconciliation by Disbursement
•
Certificate of Mailing
•
Unapplied Premium Report
•
COBRA General Notice
•
Election Notices
•
Employee Listing
System Integrator Reports
•
Activity Report
QB Identifier: Usually the social
security number (SSN).
Filter by QB Status: Choose one
or several individual selections
or “Select All” in the dropdown
menu.
View Report: Click this button to
view data on screen.
Export: In addition to viewing
data on screen, the report can
be exported to a PDF, image file,
XML file, web archive, or an Excel
document.
Page 21
ONLINE COBRA TOOLS
AD-HOC REPORT WIZARD
Follow three simple steps to create,
view, and save custom reports
containing only those fields and records
you want.
Data Selection screen: Check
boxes to select each field to
include in your report. You can
select as few or as many fields as
you want. Name your report for
easy access later from the Home
Screen.
Filtering screen: You may choose
to narrow your data results using
one or more filters. Drill down
further with the optional filter
types for each included field.
For example, create a COBRA
status report that includes
only those records where
Field=Status, Type=Contains,
and Text=Enrolled or one for
a specific QB family, where
Field=LastName, Type=Equals,
and Text=Smith.
Run and Save: Save your custom
report to be accessed or run
again at a later date. In addition
to viewing data on screen, your
ad-hoc report can be exported
to a PDF document or other
formats.
Page 22
ONLINE COBRA TOOLS
QUALIFIED BENEFICIARY ACCESS
Once they receive their login information, Qualified Beneficiaries can view and update their contact information
and enroll online to make premium payments by credit card or ACH funds transfer.
Detail Information: QB can view
his or her personal identifying
information as well as coverage
dates, COBRA status, account
balance, and payment due.
Menu tabs: QB can choose
to view/update contact
information, payments made, or
enroll to make payments online.
Data window: The requested
information appears in this
window.
Page 23
7
MONTHLY REPORTS
COBRA ADMINISTRATION MONTHLY INVOICE
The monthly invoice will include:
•
•
A total of all payments received for the invoiced month, less any
•
administrative fees
•
refund checks to COBRA members
•
NSF checks (non-sufficient funds)
•
carrier payments for the invoiced month
Monthly activity update
•
Total COBRA notifications mailed for the invoiced month
•
Total active COBRA participants for the invoiced month
•
Any other debits/credits owed to the group for the invoiced month
COBRA ADMINISTRATION STANDARD REPORTING
AmeriHealth Administrators will send monthly reports of all COBRA activity for your plan. Your company
will receive a report even if you have not had recent activity on your account. The standard monthend reporting package will include:
Monthly Invoice Summary
This report summarizes the premiums and notifications processed.
MONTHLY INVOICE SUMMARY
This is a sample of what your Monthly
Invoice Summary report might look like.
Employer name
Premiums collected
PEPM (per employee per month)
cost
2% administrative allowance
Premiums refunded to individuals
Non-sufficient funds (NSF)
Monthly COBRA activity summary
Additional credits/debits
I
Insurance carriers
Based on the COBRA administration
needs for your plan, your invoice
Summary may look different.
If you have any questions about
this report, please contact your
Administration representative.
Page 24
MONTHLY REPORTS
Voucher Report
This report displays details on the premiums received during the month. It lists all Qualified Beneficiaries
who have made premium payments, the amount paid for each benefit (medical, dental, etc.), and for
which month the payment will be credited.
You may use this report to reconcile amounts received from COBRA participants and payments made
to your insurance carriers.
VOUCHER REPORT
Page 25
Employer name
Invoice date range
Qualified beneficiary (QB)
ID number
Check number
Payment amount
Amounts due
Total premiums received
(for date range)
MONTHLY REPORTS
Primary Qualified Beneficiaries (PQB) Listings report
This report provides a listing of all active COBRA members during the invoiced month.
PQB ACTIVE LISTINGS REPORT
Employer name
Qualified beneficiary (QB)
ID numbers
Branch name (if applicable)
Monthly premiums totals
Notification Letter Issued Report
This report displays all the members that you have informed us have experienced a COBRA Qualifying
Event and were sent an election notice during the invoiced month, and the time remaining—as of the
report date—for the member to elect COBRA coverage.
Please review this report each month to ensure that AmeriHealth has notified all participants as
requested.
NOTIFICATION LETTER
ISSUED REPORT
Page 26
Employer name
Invoice date range
Qualified event (QE) date
Date notification processed
Days remaining for QB to elect
COBRA coverage
A
S
Page 27
APPENDIX: SAMPLE FORMS
This appendix includes copies of the forms listed below.
•
Sample Content: Severance Letter
•
Group Health Plan Designated Contact Form
SAMPLE CONTENT: SEVERANCE LETTER
Joe Smith
123 N. Main St.
Anytown, PA 12345
Dear Mr. Smith:
This notice contains important information about your Separation of Employment Agreement and
your right to continue your Health Benefits under the «Group Name» Group Health Plan.
COBRA eligibility begins on the first day of the month following the date of your termination
from the company and extends for a period of 18 months thereafter. In the event you elect
to execute the Separation of Employment Agreement and General Release (“Severance
Agreement”), premiums for health coverage (less applicable associate contributions, which will
be taken from your severance payments) will be paid from «FirstOfMonthAfterTermination» through
«EndOfMonthSeveranceEnds» as indicated in your Severance Agreement. Should you wish to
continue your health benefits, you will be responsible for payment from «FirstOfMonthSeveranceEnds»
through the end of your eligibility period. Please be aware that in order to continue these benefits,
you must submit the enclosed Health Benefits Continuation Plan Enrollment Form within the time
period as indicated in the enclosed COBRA Packet. Please note that the time period wherein your
health benefits are paid by the company runs concurrently with your COBRA eligibility period.
Should you choose not to execute the Severance Agreement, but would like to continue your health
coverage under COBRA, you will be responsible for payment from «FirstOfMonthAfterTermination»
through the end of your eligibility period. The date on the Health Benefits Continuation Plan
Enrollment Form is the date you became eligible for COBRA and from which your eligibility period is
established.
Please note that if you have a Health Flexible Spending Account (FSA), it does not run concurrent
with your Severance Period. If you choose to continue your FSA, the first premium due will be due
«FirstOfMonthAfterTermination».
If you have any questions, please feel free to contact (XXX) XXX-XXXX.
Sincerely,
Benefits Specialist
Group Health Plan
Designated Contact Form
HIPAA requires that a group health plan handle all interchanges of data that contain Protected
Health Information (PHI) as follows:
•
All group health plans must provide a designated group health plan contact name and
address or group health plan contact title and address. The designee must be, an
employee of the group health plan (or the plan sponsor) and cannot be a business
associate of the group unless specifically requested by the group in writing.
•
Reports containing PHI will meet the HIPAA Privacy Rule and applicable state(s)
requirements.
•
A disclaimer will be placed on all reports and other communications to the group health
plan that may contain PHI stating that the PHI is being furnished to the group health plan
designee only.
Please complete all information and return to your marketing representative.
Group Name:
Designated Contact Name:
Designated Contact Title:
Mailing Address:
E-mail Address:
Telephone Number:
Fax Number:
I certify that the person or title listed above is an employee or designee of the group
health plan or the plan sponsor. I further certify that I am an officer of the group
authorized to make this designation. This designation will remain in effect unless
revoked or changed, in writing, by an authorized officer of the group.
Authorized Officer’s Name:
Authorized Signature:
Title:
Date:
www.ahatpa.com
Page 29
COBRA-admin-gd-er_1205

COBRA ADMINISTRATION SERVICES

Transcription

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