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Group Benefits

ARRA (The American Recovery & Reinvestment Act of 2009) Update

The COBRA ARRA Model Notices were released yesterday morning. Most of our carriers
are still working on their response to the Model Notices and to the administration of the COBRA Continuation Coverage Assistance. Rather than waiting for the insurance carriers to respond, Resource Brokerage wants  to make sure you have the current legislative information.
Click here for the four COBRA ARRA model notices. The notices include General Notices (both Full and Abbreviated versions), an Alternative Notice for those who fall under state Continuation, and a notice for those former employees that fall under the extended election period. 

 

For Your COBRA Groups

It is our understanding that the COBRA Continuation Coverage Assistance will match what we outlined in our prior email. The group or the group’s COBRA administrator must  notify, administer, and submit paperwork showing their reimbursement. If you need a refresher on that mailing, here is the link. The only major update that we have seen is the method of reimbursement for the Employer. They will use the Form 941 to report their costs. Click here for sample 941. Click here for instructions.

 

For Your IL Continuation Groups

It is clear that the ARRA legislation does include Illinois Continuation, and the big difference between the under 20 and 20+ life groups is that the insurers are required to front the 65% subsidy (as opposed to the employers) and adjust their employer billing to 35% of the applicable rate.

The major item that has not been resolved involves the former insureds that became Continuation eligible from 9/1/08 to 2/16/09.  The state legislature has been tasked to determine whether the ARRA legislation will apply to these individuals. 

It also should be noted that although it appears that the groups’  responsibilities in administering the ARRA legislation may be minimal, your groups will be required to provide the carriers with a listing of all involuntarily terminated employees that became eligible from 9/1/08 forward.  Once the legislators have notified the carriers of their administration guidelines, Resource Brokerage will provide that information to you.


Additional Information:

Click here for Department of Labor COBRA Premium Reduction FAQs
Click here for DOI Federal Stimulus FAQs

 

This review is meant for Resource Brokerage, LLC brokers only and is provided for broker informational purposes only and is not intended to be quoted or relied upon as legal or tax advice. 

 

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Resource Brokerage, LLC | 1501 East Woodfield Road, Suite 110E | Schaumburg, IL 60173-4945
phone: (800) 605-7566 | fax: (847) 605-1494
www.resourcebrokerage.com
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