Travis Software Announces Plans to Begin Removing ARRA Notification and Subsidy Capabilities
Houston, Texas, December 09, 2009 -
While Congress is considering extending the COBRA Premium subsidy provided by ARRA there remains the possibility that January 1, 2010 will come and go without ARRA being extended. If no extension is enacted, those who have qualifying events in 2010 will not be eligible to become Assistance Eligible Individuals (AEIs) under ARRA, as ARRA only provides for subsidy for those who have qualifying events between September 1, 2008 and December 31, 2009.
Each employer or administrator should be thinking about how you want to administer a "wrinkle" in the ARRA law concerning people who have qualifying events late in 2009 and whose "First Day After Loss of Coverage" is January 1, 2010 or later. There are many who believe that those who have their qualifying event late in 2009, or even on December 31,2009, but their "First Day After Loss of Coverage" is January 1, 2010 or later, are not eligible to become "AEIs" and receive subsidy assistance. Other employers and administrators believe that as long as the qualifying event date is on or before December 31, 2009, the person is eligible for the subsidy. There has been no clear guidance from the Department of Labor on this question, so administrators are left to decide for themselves how to address the issue.
Both the TravisCobra and WebCobra.com systems have been modified to help users out of ARRA.
First, both the current version of TravisCobra (Series 8.5.0.03) and the current production version of WebCOBRA.com have been programmed to stop including wording, forms, etc. in the COBRA Election Notice package concerning ARRA, and stop mentioning the possibility of a qualifying beneficiary becoming an AEI, if the qualifying event date is January 1, 2010 or later. TravisCobra users should make sure they are on Release 8.5.0.03 and if they are not, please contact TravisSupport to get help downloading and installing that version. WebCOBRA.com users are always on the most current version of the system and need to do nothing.
If the qualifying event date for a new QB is during the latter part of 2009 and the "First Day After Loss of Coverage" is 1/1/2010 or later, then the systems have "Custom Options" you can set to fit your interpretation of the law. Administrators using multi-employer versions of TravisCobra and WebCOBRA.com can set this option globally for all employers or may set it on an employer-by-employer basis.
Both systems will continue to help users administer the ARRA subsidies for existing AEIs during their nine-month subsidy term as we move into 2010. So, for example, if someone had a qualifying event on September 30, 2009 and was qualified to be an AEI, the systems will account for their subsidy through June, 2010. Anyone with a qualifying event date in 2010 will not be provided wording in their letters offering them the opportunity to become AEIs.
All this may change if Congress acts to extend ARRA, and Travis is watching those deliberations closely. One proposal being considered calls for an extension of the ARRA COBRA subsidy to 15 months, which would probably require another renotification to the various types of affected QBs and some modified premium accounting.
Travis is watching the developments in Congress, and will respond quickly with new releases if there is an extension of ARRA passed. But if Congress does not act, both TravisCobra and WebCOBRA.com are ready to handle the transition to a "post-ARRA" world.
Travis Software Corp. is the leader in providing COBRA software to TPAs, employers and COBRA administrators across the country. Founded in 1986, the Houston-based company has over 2,000 administrators using its TravisCobra and WebCOBRA.com systems nationwide.
About Travis Software Corp.
Travis Software Corp., based in Houston, Texas, was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the company's COBRA administration software system, TravisCobra, and its Web-based system for COBRA, WebCOBRA.com.
Trademarks
WebCOBRA.com is a trademark of Travis Software Corp. Microsoft and SQL Server are registered trademarks of Microsoft Corporation in the United States and/or other countries.
For more information about the WebCOBRA.com Fall '09 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.