A new COBRA administrator is now in place for CalCPA-member firms with employees enrolled in the Group Insurance Trust’s medical, dental and vision plans. As subscribers are probably aware, at the beginning of 2010, Banyan Administrators, LLC replaced Seabury & Smith as administrator of the Trust’s group insurance plans. Seabury previously had provided COBRA and CalCOBRA administration to CalCPA plan members. However, with the administrative transition, the Trust found it necessary to contract with a secondary administrator for these services. After a lengthy search, the Trust engaged Infinisource, a leader in COBRA and CalCOBRA administration, to provide member firms with these specialized services.

Founded in 1986 to help employers and insurance professionals navigate complex benefit-related federal regulations, Infinisource has streamlined the complex and time-consuming procedures that all firms must adhere to. Benefit managers and individual members will be pleased to find that the new online tracking capacities now available through Infinisource will make it easier both to track payments and comply with regulations.

Administrative Procedures

Firms with an average of 20 or more employees in the previous calendar year, and, thus subject to COBRA, must contract directly with Infinisource. These firms may, however, choose to contract directly with another COBRA administrator or to self-administer these benefits. The Trust will, however, absorb the costs of administration for firms selecting Infinisource as their provider. The Trust contracts directly with Infinisource on behalf of its CalCOBRA firms (i.e., those with 2–19 employees). Whether employees qualify for COBRA or CalCOBRA, firm administrators should communicate all qualifying event information to Banyan Administrators.

The “COBRA/CalCOBRA Notice and Notification Form” is available online at the ProtectPlus website (www.cpaprotectplus.com). To access the form, click through “Rates & Forms” on the menu bar and choose “other.” The completed form should be mailed or faxed to Banyan within 30 days of the qualifying event for COBRA, or 31 days for CalCOBRA. If you need any help completing the form, call Banyan Administrators at (877) 480-7923. The form contains a checkbox for each legally defined “qualifying event” as well as a line asking whether termination was voluntary or involuntary. If the firm has contracted (or wants to contract) with Infinisource, Banyan will convey this information to Infinisource, which will determine if former employees qualify for benefits. If they do, Infinisource will set up an online tracking system and, at the same time, send out a Qualifying Event Notice with a user ID and password for gaining access to that information. Infinisource will handle the billing to CalCOBRA/COBRA members directly, and it will also bill COBRA firms for the subsidy portion that they owe on their ex-employees’ premiums.

Former employees who have exhausted their 18-month COBRA benefits have the option to continue their coverage under CalCOBRA. In advance of their COBRA termination, they will receive an election package from Infinisource to continue on CalCOBRA.

ARRA Continuation

Beginning February 17, 2009 the American Recovery and Reinvestment Act (ARRA) offered individuals who would ordinarily qualify for COBRA coverage—and whose income fell below a specified level—the opportunity to continue COBRA coverage at a reduced cost. It also offered these individuals the opportunity to newly enroll in COBRA.

On April 15, 2010 the benefits of the ARRA were extended by HR 4851 until May 31, 2010 for qualifying events on or after September 1, 2008. For eligible individuals, the federal government subsidizes 65 percent of COBRA premiums while the individual subscriber pays 35 percent. Under the legislation, premiums for medical, dental, and vision policies can be covered for a maximum of 15 months. As with COBRA and CalCOBRA, Infinisource administers this program for ProtectPlus subscriber firms and their former employees.

Nevertheless, since further legislation is pending in the House that would again extend this program, firms should keep themselves informed. In addition, Infinisource will work with employers to make sure that they stay in compliance.

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