Texas CE Course Certification
COBRA – The Main Course3.0 Hours
A statement of the Knowledge, Skills, and Abilities the licensee is expected to obtain through completion of this course.
This course is designed to teach the main topics of COBRA to the licensed agent. It is designed to prepare the licensed agent to understand their liabilities and limitations in acting as a COBRA advisor for their employer clients.
A detailed outline of the course showing approximate times for major topics.
- Introduction to Course0.5 Hours
- Who should be taking this course
- What you’ll learn in this main course
- The basic rules of COBRA
- COBRA’s unique vocabulary
- The roles of the employer and plan administrator in COBRA compliance
- Action items
- Deadlines
- Required paperwork
- The duties of the QBs
- COBRA1.0 Hours
- In a nutshell
- Legal framework
- What employers are subject to COBRA
- Small employer exception
- What plans are subject to COBRA
- What is a Qualifying Event
- The seven triggering events
- The gross misconduct exception
- What is a loss of plan coverage
- Triggering event must cause loss of plan coverage
- Leaves of absences
- Mergers and acquisitions
- Severance agreements and severance pay
- Who must be offered COBRA
- QBs
- Covered “employees” may be “non-employees”
- Children as QBs
- QMCSOs
- QBs with other coverage
- Supreme Court Ruling
- Why some non-QBs can obtain COBRA coverage
- Domestic partners and their children
- Proposed legislation
- What type of coverage must be offered
- Can QBs change coverage at Open Enrollment
- HIPAA Special Enrollment Rules
- Employer modifications to plans
- Length of COBRA Coverage
- Maximum coverage
- Extensions of maximum
- The COBRA Election Process1.0 Hours
- The COBRA Election timeline
- The Qualifying Event Notice
- Employer’s notice obligations
- QBs and covered employees notice obligations
- Notice of Unavailability
- COBRA Election Notice
- When the employer is also the Plan Administrator
- COBRA Election
- COBRA Premium
- Determining “applicable premium”
- Changing the COBRA premium
- COBRA premiums
- Payment deadlines
- Other rules
- Can election and payment periods increase adverse selection?
- COBRA notices and other communications
- Two most important Notices
- Initial Notice
- Election Notice
- Other “mandatory” notices and communications
- Notice of Unavailability
- Notice of Termination of COBRA coverage
- Note: Regulatory, not statutory
- QE Notice to Plan Administrator/Employer
- Notice of COBRA premiums by Insignificant Shortage
- Open Enrollment materials
- Individual conversion policy notices
- Summary Plan Descriptions
- Summary of Material Modifications
- HIPAA Certificates of Creditable Coverage
- Disclosures to health care providers
- Notice of change in COBRA premiums
- Optional items
- IRS 98-12
- Coupon books or monthly statements
- Confirmation of COBRA Elections
- Notice of Extension of COBRA coverage
- Notice of denial of COBRA coverage due to gross misconduct
- Termination Notice at expiration of maximum coverage
- Late premium payment reminders
- Letter to dependent child regarding loss of dependent status
- Spouses or dependent children dropped from coverage
- Letter to QBs attaining age 65
- COBRA administrative procedures
- A word of caution
- COBRA administration software
- COBRA TPAs
- Consequences of “failure to comply with COBRA”
- Review of COBRA “action items” and “deadlines”
- COBRA from the QB’s point of view0.5 Hours
- Overview
- Most QBs planning starts with Election Notice
- Except employees who may be Medicare “entitled”
- Except for QBs who are or may be disabled
- QBs who have or can obtain other coverage
- Already have other coverage
- Why would QBs elect dual coverage
- QBs who can obtain other plan coverage
- Timing issues for QBs who can obtain other coverage
- QBs who elect COBRA instead of other coverage
- QBs whose elections are late
- Vast majority are timely
- Dealing with Elections that are “just a little late”
- Dealing with Elections that are “very late”
- QBs whose premiums are late
- Make sure communications say “will” terminate, not “may” terminate
- Save the postmark!
- Dealing with late payments
- QBs whose premiums are insufficient
- Significantly
- Insignificantly
- QBs who divorce with no notice to the plan
- QBs with Mini-COBRA statutes
- Employees who drop dependent coverage
- Anticipation of divorce
- COBRA in the life of Harvey and Sheila – A final review
A narrative description of how the course will be presented that speaks to the requirements of the rules.
The course will be presented in a classroom format with 90% of the scheduled time in session.