Health Care Reform Seminar

As promised, we have been researching the new health care reform law President Obama signed into law on March 23rd. Most of the major changes affecting you and your business will be phased in over time, with the majority of the major changes currently slated to go into effect in 2014. There are, however, some provisions that go into effect within a few months and on January 1, 2011.

Presentation Analysis

COBRA Subsidy Extension Update

To Our Clients:

President Obama has signed into law the Bill, H.R. 4851, which has a section that extends the federal COBRA subsidy to May 31, 2010.  Individuals “involuntarily terminated” between April 1 and May 31, 2010 are now eligible for this subsidy.

Attached is an overview of COBRA and The Recovery Act requirements for continuation of coverage.  For additional information or to download the notices required for COBRA notification, visit the Department of Labor’s website or you can contact Ann Ruf at 417-334-5115 or email aruf@akersandarney.com.

COBRA and THE RECOVERY ACT

Dependent Benefit Extension

As you are aware, the current State of Missouri dependent age limit for health care benefits is 25 (large groups of 100+ are allowed to customize their plan with regard to age limit).  Under the new Federal Heath Care Reform bill the age limit for dependents will be extended to age 26 but doesn’t take effect until September 23, 2010.

Anthem has just announced they have a new initiative that will help those dependent members facing a coverage gap during the months before the Federal provision is implemented.  Beginning June 1, 2010 Anthem will continue to provide health benefits to those dependents that would otherwise lose coverage because of their age, student status or other factors during the gap period between June 1, 2010 and September 23, 2010.  Attached is a Q&A document provided by Anthem with information that will hopefully address your questions regarding this new initiative.

Anthem Extension of Benefits

COBRA Subsidy Update

Previously we informed you the COBRA Subsidy program had been extended to March 31, 2010 and that there was a possibility it might be extended to the end of April 2010 or possibly through the end of the year if pending legislation was passed.  It is our understanding the Senate members adjourned for the Easter break without voting on the House-approved legislation that would have extended the program through April.  When Congress returns on April 12 it is expected they’ll seek to provide benefits retroactively to April 1, 2010.  We will update you as information becomes available.

Should you have any questions please contact Ann Ruf at 417-334-5115 or email aruf@akersandarney.com.

Health Care Reform

The passage of health care reform in Washington will potentially have a significant impact on all of us over the coming years.  Careful analysis of the legislation and the expected impact is underway as we speak. 

Some provisions of the program will be implemented in the near future, however most of the major reforms do not go into effect until January 1, 2014 for businesses with fewer than 100 employees and 2017 for those with over 100.

Our Benefits team is scheduled to attend a webinar tomorrow through the lunch hour to educate ourselves on the latest updates.  We will be putting together an executive summary of our findings to share with each of you for use by your respective organizations.  Please do not hesitate to contact us with specific questions, and we will endeavor to get you an answer.

COBRA Subsidy Extension

On March 2, 2010 the U.S. Senate passed the Temporary Extension Act of 2010 and the President signed the bill into law on March 2, 2010. The Temporary Extension Act extends the COBRA subsidy program that was enacted under the American Recovery and Reinvestment Act (ARRA) to provide a 15-month 65 percent premium subsidy to those involuntarily terminated from March 1 through March 31, 2010. The law also allows employees to receive the subsidy if they first lost group coverage due to a reduction in hours and then were terminated after enactment of the bill.

These short term extensions of the COBRA subsidy benefit (it was recently previously to February 28, 2010) is intended to give Congress more time to consider legislation to extend the program through December 31, 2010.

We will keep you advised of any information we receive.

COBRA ARRA Extension Notices

As we notified you last week, the ARRA COBRA subsidy was amended to extend the eligibility period to February 28, 2010 as well as extend the benefit period from 9 months to 15 months.

This amendment was part of the Department of Defense Appropriation Act, 2010 and the Department created “Model Notices” to help you and your COBRA eligible members comply with these new requirements. Each model notice is designed for a particular group of qualified beneficiaries and contains information to help you satisfy ARRA’s notice provisions.

Updated General Notice

This notice should go to all qualified beneficiaries (not just covered employees) who experienced a qualifying event at any time from September 1, 2008 through February 28, 2010, regardless of the type of qualifying event, and who have not yet been provided an election notice. Individuals who experienced a qualifying event (that was a termination of employment) in December 2009 but who were not eligible for COBRA coverage until January 2010 were probably not provided proper notice and should get the updated General Notice and the full 60 days from the date the updated notice is provided to make a COBRA election.

Model Premium Assistance Extension Notice

This notice should be provided to individuals who have already been provided a COBRA election notice that did not include information about the amended ARRA. Listed below are the affected individuals and the associated timing requirements.

1. Individuals who were “assistance eligible individuals” as of October 31, 2009 and those who experienced a termination of employment on or after October 31, 2009 and lost health coverage (unless they were already provided a timely, updated General Notice) must be provided notice of the changes made to the premium reduction; and

2. Individuals who are in a “transition period” must be provided this notice within 60 days of the first day of the transition period. An individual’s “transition period” is the period that begins immediately after the end of the maximum number of months (was 9 months) of premium reduction prior to the amendment. They are in a “transition period” only if the premium reduction provisions would continue to apply due to the extension from 9 to 15 months and they otherwise remain eligible for the premium reduction.

Should you have questions please call or email Ann Ruf at aruf@akersandarney.com.

ARRA COBRA Subsidy Extension Update

Back in December 2009 we sent an email to you advising the ARRA COBRA subsidy bill (HR 3326) that would extend the subsidy coverage period would more than likely be signed into law. The President signed the bill on December 19, 2009 and below is the information I have been able to compile to date:

1. ARRA COBRA subsidy recipients whose eligibility was scheduled to end on December 31, 2009 will now be extended through February 28, 2010.

2. The subsidy period was extended from 9 months to 15 months for all assistance eligible individuals.

3.Those whose subsidy ended on November 30, 2009 (they reached the 9 months limit) now have a grace period of 60 days to pay their COBRA premium and extend their coverage.

4. Employers are to notify those who lost their subsidy on November 30, 2009 of their extended payment grace period (60 days).

5. Employers are to also notify anyone who was eligible as of October 31, 2009 or later of the subsidy changes.

I have been monitoring the Department of Labor web site for information and model notifications but have not found anything posted as of this writing.

There is also a possibility that the subsidy period will be extended to June 30, 2010 rather than February 28, 2010. We will advise everyone regarding this additional extension as soon as the information is available.

ARRA Subsidy Extension

Just a quick notice to everyone regarding the COBRA subsidy extension. We’ve learned that Congress has passed (and the President is expected to sign) an extension to the COBRA premium subsidy that was scheduled to end on 12/31/09. When we have all of the new rules/guidelines we will make that available to quickly as possible.

Important Information About the American Recovery and Reinvestment Act of 2009 (ARRA)

On February 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act of 2009 (ARRA), which, among other things, provides for a nine (9) month subsidy of COBRA premiums for employees who are involuntarily terminated. The law also subjects employers to additional administrative and notice requirements.

As you know, COBRA is a federal law that provides former employees and eligible dependents the right to retain their health insurance coverage, generally up to 18 months, after losing their job. The former employee and/or dependent must pay the full premium, which can be very expensive. Under the recently enacted ARRA, eligible former employees and their dependents, enrolled in their employer’s health plan at the time they lost their jobs, are required to pay only 35% of the cost of COBRA coverage. Employers must treat the 35% payment by eligible former employees as full payment, but the employer is entitled to a credit for the other 65% of the COBRA cost on their payroll tax return. The employer must maintain supporting documentation for the credit claimed. The eligible former employee and their dependents are entitled to the 65% COBRA health insurance premium subsidy for up to 9 months. Even if your company does not have to comply with the federal COBRA law because it has fewer than 20 employees, it must comply with the COBRA subsidy if it is covered by a COBRA-type State Continuation law.

Under the subsidy program the federal government will help pay for the COBRA benefit of any individual who is involuntarily terminated between September 1, 2008 and December 31, 2009 and whose income in the year of the subsidy does not exceed $125,000 for an individual or $250,000 for those filing joint returns. Taxpayers with modified adjusted gross income exceeding $145,000, or $290,000 for those filing joint returns, do not qualify.

The ARRA provides eligible individuals a special 60-day period to elect subsidized COBRA continuation coverage. Notice of this right must be sent to otherwise-eligible individuals no later than April 18, 2009, even if they declined COBRA coverage in the past. This notice may be supplied via a modified COBRA notice or in a separate document. The Secretary of Labor is charged with issuing form notices for this purpose by March 17, 2009 and as soon as the forms are available we will forward a copy to you.

This special 60-day election period starts the day the eligible individual is provided notice regarding the availability of the COBRA subsidy. If an eligible individual who terminates prior to March 1, 2009 elects. COBRA coverage after receiving the special 60-day election notice, then coverage begins on March 1, 2009, not on the date of the individual’s qualifying event. The extended election period does not extend the period of COBRA continuation coverage beyond what would have been available if COBRA had been initially elected. If an employee was laid off after September 1, 2008 and declined COBRA coverage, the employer must give that employee another chance to elect coverage. Businesses must notify all COBRA-eligible individuals of the subsidy and ordinary COBRA benefits.

We will continue, in the weeks ahead, to help our clients implement this crucial change. Any additional information we obtain regarding the details will be forwarded to you. In the meantime, if you have any questions or concerns please contact us.

Medicare Annual Election Period

Government sponsored healthcare coverage for seniors is a confusing subject and never more so than during the Annual Election Period for Medicare, which runs Nov. 15- Dec. 31, 2008.

Akers & Arney is a trusted advisor to many seniors who seek help with their Medicare and supplemental health plans during Medicare’s Annual Election Period. Agent Linda Baxter is available to answer question on a variety of plans including the Missouri Rx Plan, Medicare’s Extra Help Plan, the Missouri AIDS Drug Assistance Program (ADAP), and the Medicare Savings Programs.

Linda specializes in helping seniors find affordable health and life insurance solutions that offer the best coverage available on the market today. Linda has 15 years of experience in the corporate benefits and individual health and life insurance industry. I encourage you to visit with Linda today about all your Medicare, small group, and individual health and life insurance solutions. Call (417) 334-5115.