Insurance Law: COBRA

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TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

Table of Contents

Foreword
Introduction
CHAPTER 1: COBRA Basics
CHAPTER 2: COBRA Noncompliance
CHAPTER 3: Case Analysis
TEST

Foreword

This course is based on our understanding and interpretation of COBRA. As any legal researcher will tell you, “Statutes are interpreted by courts.” Just because one may read a statute and thinks he understands what it says, that does not necessarily mean a court will interpret it in the same manner. Common usage of words and legalese can be two totally different things. One may assume that there is much case law concerning COBRA to help one fully understand its legal application. In this regard, one cannot assume this course as authoritative, but must seek legal counsel for actual implementation, legal interpretation and integration of COBRA into any employer provided group health insurance plan.

Besides federal COBRA law, which this course is tailored after, individual states have their own COBRA statutes. If one were to take the time and peruse a sampling of several states, he would find their statutes to be almost identical in content and application as the federal. However, in establishing corporate guidelines for integrating COBRA into one’s group health insurance plan, one should peruse both state and federal statutes to ensure complete compliance.

Since this course concerns tax law, well, it is always changing. It would be prudent to peruse the most recent statutes to ensure that you have current knowledge. Even though we attempt to stay current and provide the most recent information, it is not always possible.

TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

Introduction
Insurability · Insurance Rates · Guaranteed Renewable
Comprehensive Coverage · Class Elimination · Preexisting Conditions
Waiting Periods · Uninsurable Risks · Co-Pay and Deductibles

Many people can probably remember the days when certain events such as the termination or death of an employee meant that the family had to make hard choices concerning their health insurance, which was about to disappear. Of course, this was all before the passage of the Continuation Benefits Replacement Act, more popularly known as COBRA, which is codified in Internal Revenue Code section 4980B (IRC 4980B). COBRA refers to the above events as Qualifying Events (discussed in more detail later), which, in a nutshell, are situations concerning an employee that puts the employee and other family members at risk of losing their health insurance coverage.

Before COBRA, what did one do if such a Qualifying Event occurred? Well, there were certainly no good choices. Basically, one would have to shop around for new insurance or do without. For many, those weren’t viable options. Here’s a summary of some of the repercussions.

Insurability
Insurability is one’s ability to obtain health insurance. While one was employed, this was not a concern for the employee or any family member. Even if a member of the family had acquired a disease or injury that would require years of expensive treatment, this was also not an issue because the employer’s health insurance company already covered them. What if all of a sudden the family lost their health insurance because of a Qualifying Event? Well, they would basically be up the creek without a paddle. They would have to apply for new health insurance with a new insurance company that would take a fresh look at all the members of the family who would be insured. From the insurance company’s perspective, they would not want to insure any existing conditions that they know would cost them money now or in the reasonable future. Any such condition can cause one to become uninsurable. For example, most health insurance companies will not cover many types of cancers or heart conditions – period – either until a certain time elapsed from the last incident of treatment or forever.

Insurance Rates
While one is employed, he benefits from the pooling effect of group health insurance. Generally, the larger the group, and depending upon the types of health risks that are associated with the employer, the lower the costs. Of course, an insurance company’s claims experience always affects costs, but those costs would be spread out more with a larger group and may be more determinable. Of course, this does not always guarantee that costs will be lower than if one purchased health insurance on an individual basis. However, while one is employed, he may benefit from the employer paying part or all of the cost of health insurance.

If an employee changed jobs and was able to be accepted into the new group with no strings attached, then other family members would have no cause to fret. However, most of the reasons for losing health insurance (Qualifying Events) leave family members out of the ‘group loop’ causing them to seek coverage on an individual basis on their own merits of insurability. Individual health insurance rates vary dramatically from company to company and some even participate in underwriting discounting, which means that the initial rates are discounted to compete until a certain time elapses then the real costs appear through a series of rate increases.

Guaranteed Renewable
This is not a problem nowadays, but many types of health insurance were not always guaranteed renewable. Now, it is really a non-issue.

Comprehensive Coverage
Employer provided group health insurance coverage, for the most part, has always been fairly comprehensive, covering just about most things under the sun with certain limitations. This has always been a major drawing card for attracting and keeping quality employees. An employee could depend upon the employer’s diligence to ensure that coverage was adequate and comprehensive. If one lost his coverage, then he would have to go through the learning curve and compare various types of coverage from various companies. Just discerning the meaning of lingo would be a challenge. It would now be up to the individual to determine things such as, “How comprehensive is Major Medical,” or what does “Usual and Customary” really mean?

Class Elimination
Many folks who own individual health insurance policies have experienced class elimination. This takes place when a particular health insurance company determines that a certain ‘class’ or ‘book’ of business, which is basically attributed to a specific type of policy, is no longer profitable. Since health insurance policies are generally guaranteed renewable, the only option for the insurer is to raise premiums so high that insureds will either drop the policy or pay exorbitant premiums.

Well, for those who have maintained good health and stayed insurable, this poses no problem. They can go elsewhere and obtain new coverage with little hassle. However, what about those who have become uninsurable while being previously covered? They either have the choice of dropping the coverage and doing without or paying high premiums causing them to forsake other needs. Either way, the financial results can be devastating.

Preexisting Conditions
A preexisting condition is a medical condition that exists prior to one taking out new health insurance coverage. Typically, group health insurance plans will cover all preexisting conditions for new employees (subject to Chapter 100 of the IRC). However, before COBRA, most Qualifying Events rendered family members without the benefit of continued group health insurance. Their only option was individual health insurance, which meant that the new insurance company examined every preexisting condition. Depending upon the condition, the insurance company would either (1) totally exclude covering anything attributed to the treatment of such condition, (2) include covering anything attributed to the treatment of such condition after a certain time, or (3) totally exclude the individual from any type of coverage.

Waiting Periods
New coverage means starting anew for the coverage to take place. Most medical conditions are not covered immediately but have a waiting period. Maternity benefits, for example, will not be covered for nine months. For those with preexisting conditions that are conditionally covered under a new policy, they will usually have to have no needed treatment for a specific time period for the condition to be covered. Other conditions may be covered unconditionally after a certain timeframe. One can quickly see how a Qualifying Event can immediately put one in a financial bind.

Uninsurable Risks
Since every insurance company has different claims experience, each will have its own set of risks that they consider uninsurable. For one who has experienced a Qualifying Event leaving him without group health insurance coverage, this can be a rude awakening.

Co-Pay and Deductibles
Premiums rise and fall with the amount of co-pay and deductible one assumes. The deductible is the first dollar out-of-pocket expense paid by the insured. For example, if one has a $500 deductible and $1,000 hospital bill, the individual pays the first $500 before anything else takes place. Next, the amount of co-pay is determined and is defined on a percentage basis. In the same scenario above, we’ll assume that the policy has an 80/20 co-pay. This means that for the remaining $500, the insurance company will pay 80% ($400) and the insured will pay 20% ($100).

In a typical group health insurance plan, co-pays and deductibles are usually very reasonable. However, if one loses such insurance and has to find an individual plan, then these amounts can vary dramatically from company to company. This can pose a problem when trying to fit premiums into a tight budget. A higher co-pay percentage on the insured’s part means a lower premium and vice-versa. A higher deductible means a lower premium and vice-versa. Lower premiums are nice to have, but if one uses the insurance frequently, a higher deductible and co-pay can quickly be a financial drain. As a rule, one should increase cash reserves as he increases his co-pay and deductible.

TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

CHAPTER 1: COBRA Basics
Qualifying Event · Qualified Beneficiary · Election Period · Type of Coverage
Period of Coverage · Premiums · Notice Requirements

Well, now that we have covered a little bit of how it used to be before COBRA, let’s move on to the nuts and bolts of COBRA and how it applies today. One needs to be aware that COBRA only applies to group health insurance, not personal health insurance. Since not all health plans are created equal, COBRA defines a group health plan (IRC 5000(b)(1)) as, “A plan (including a self-insured plan) of, or contributed to by, an employer (including a self-employed person) or employee organization to provide health care (directly or otherwise) to the employees, former employees, the employer, others associated or formerly associated with the employer in a business relationship, or their families.” Basically, COBRA was designed to give certain people the right to continue group health insurance for a specific time when certain conditions caused them to lose or would cause them to lose it.

QUALIFYING EVENT

Previously, we discussed Qualifying Events that put employees and family members at risk of losing group health insurance benefits. A Qualifying Event (IRC 4980B(f)(3)) means the following events concerning an employee that, but for continuation of health insurance coverage required under the law, would result in the loss of health insurance coverage of a qualified beneficiary –

  • The death of the employee.

  • Other than gross misconduct, the termination or reduction of hours of the employee. (Note: The term “gross misconduct” is more subjective and therefore subject to interpretation. Employers should clearly articulate what “gross misconduct” means.)

  • The employee divorcing or obtaining a legal separation from his or her spouse.

  • The employee qualifying for Medicare benefits (Title 18 of the Social Security Act).

  • A dependent child no longer a dependent.

  • The retired employee’s employer participating in a bankruptcy proceeding.

QUALIFIED BENEFICIARY

Well, just because a Qualifying Event takes place, it does not mean that a family member has the right to continue group health insurance coverage. As stated above, one must be a Qualified Beneficiary (IRC 4890B(g)(1)), which is defined below, to receive the protections of COBRA:

  • The spouse of the employee and a beneficiary under the group health insurance plan the day before the Qualifying Event.

  • The dependent child of the employee and a beneficiary under the group health insurance plan the day before the Qualifying Event. During any period of coverage continuation, children born to or placed for adoption by the employee are also covered.

  • Other than gross misconduct, an employee who has been terminated or has had a reduction in working hours.

  • Other than the above, a nonresident alien is excluded during any time in which he derived no earned income from a source within the U.S.

  • In the case of the employer participating in a bankruptcy proceeding, an employee retiring on or before the date there was a substantial reduction in health insurance coverage. This also includes any other person who, on the day before this event, is a beneficiary under the group health insurance plan as:

    • The spouse of the covered employee,

    • The dependent child of the covered employee, or

    • The Surviving spouse of the covered employee.

Let’s elaborate on some of the above Qualified Beneficiaries. Family members are only covered under COBRA if they were previously insured under the group health plan. Even if a non-employee spouse becomes divorced, COBRA protections do not extend to that person unless previously covered under the group plan before becoming divorced. The same applies for dependent children who would otherwise not be covered under the group plan after certain events such as attaining a specific age, getting married, etc. For example, Jack’s group plan will cover Jack Jr. until his 21st birthday. However, if Jack Jr. is not covered under the plan when he turns 21, he has no rights under COBRA.

If one is a Qualified Beneficiary but his group health plan fails COBRA requirements, the plan shall subsequently be considered compliant if –

  • The prior deficiencies are retroactively undone to the extent possible, and

  • The Qualified Beneficiary is placed in a financial position that is as good as she would have been if the failure had not occurred. For this part to apply, the Qualified Beneficiary shall be treated as if she had elected the most favorable coverage in light of the expenses she incurred since the failure first occurred.

Mary is the widow of Jack, who was previously employed at ABC Enterprises, Inc. Both were covered under Jack’s group health insurance plan before he died. Five weeks after Jack’s death, Mary fell and broke her hip. She was in the hospital for several days followed by several months of recuperation as well as therapy. Assuming that she had insurance, she disregarded the bills after informing the hospital’s billing office of her coverage, which did not exist. Jack’s death was a Qualifying Event and should have been reported to the plan administrator by his employer within 30 days per the terms of the group plan; and, the administrator should have notified Mary of her rights to continuation coverage. However, the company was going through some internal changes and the required notice was overlooked. When this error was discovered, the company retroactively covered Mary with the best possible option available for continuation coverage and placed her in the most favorable position as if the oversight had never occurred. Originally, the company was noncompliant with COBRA and was subject to tax penalties. However, because the company took immediate action to correct their failure, they were exempt from any penalties.

Now that we have discussed who is protected under COBRA and the conditions that give rise to that protection, let’s move on to some of COBRA’s nuts and bolts. Generally, a group health plan meets COBRA requirements if a Qualified Beneficiary who would lose coverage under the plan as a result of a Qualifying Event is entitled to elect, within the election period, continuation coverage under the plan (IRC 4980B(f)(1)).

ELECTION PERIOD

Well, we are introduced to the procedure that a Qualified Beneficiary is entitled to after a Qualifying Event takes place - he is entitled to make an election to continue group health coverage and is allowed to do so within a designated time frame, all of which must be spelled out and made available to all Qualified Beneficiaries.

The term “election period” (IRC 4980B(5)(A)) means the period that –

  • Begins not later than the date on which the coverage terminates as a result of a Qualifying Event,

  • Is at least 60 days in duration, and

  • Ends no earlier than 60 days after the later of –

    • The date on which coverage ends as a result of a Qualifying Event, or

    • In the case of any Qualified Beneficiary who receives a required Notice from the plan administrator, the date of such notice.

Let’s consider the case of Joe Public who was terminated on March 1. Of course, his group health insurance coverage would terminate on the same date. However, a few days later, he received a notice (dated March 3) from his employer’s insurance plan administrator that he has the right to continue his health insurance coverage under the COBRA law. So, as far as his election period is concerned, the clock started running on March 3, the date of the required notice from the administrator. Even though he was terminated on March 1, the clock started running on the latter of the two dates. Considering this, he has until May 1, which is 60 days later (inclusive), to elect to continue health insurance coverage.

Considering the fact that there may be multiple Qualified Beneficiaries, COBRA mandates that if any Qualified Beneficiary makes an election to continue coverage as a result of a Qualifying Event, then that election shall be deemed to include all other Qualified Beneficiaries who would lose coverage under the same event (IRC 4980B(f)(5)(B)). However, this does not mean that all beneficiaries would have to select the same coverage. In fact, if there is a choice among types of coverage, each beneficiary is entitled to select the coverage that fits his or her needs.

Above, Joe Public had COBRA rights to continue health coverage. What about the rest of his family? Well, assuming his wife and children were covered under the group health plan the day before he was terminated, they all would have continuation coverage even if Joe were the only one who chose to do so. COBRA mandates that only one Qualifying Beneficiary is required to make an election – all other Qualified Beneficiaries are automatically included. If Mrs. Public were pregnant during this transition time and gave birth during the period of continuation coverage, their newborn would automatically be covered as well.

TYPE OF COVERAGE

After a Qualifying Event, the coverage that is provided to Qualified Beneficiaries must be identical to the coverage provided to similarly situated beneficiaries to whom a Qualifying Event has not occurred (IRC 4980B(f)(2)(A)). In other words, continuation coverage cannot be inferior to the existing group coverage. If the group coverage is modified for similarly situated beneficiaries, then it must also be modified in the same manner for all Qualified Beneficiaries.

PERIOD OF COVERAGE

Coverage for Qualified Beneficiaries must continue for a period of time beginning on the date of the Qualifying Event and ending not earlier than the earliest of the following (IRC 4980B(f)(2)(B)):

  • The date that the employer ceases to provide any group health coverage for any employee.

  • The Qualified Beneficiary fails to pay the required premium in a timely fashion. A payment will be considered timely if made within 30 days (grace period) after the premium due date or later if a longer grace period is allowed under the terms of the plan.

  • The date on which the Qualified Beneficiary first becomes, after the date an election is made to continue coverage under COBRA, covered under another group health plan, which does not contain any exclusion or limitation with respect to any preexisting condition of the beneficiary.

  • The date on which the Qualified Beneficiary first becomes, after the date an election is made to continue coverage under COBRA, entitled to Medicare.

  • In the case of a Qualified Beneficiary who becomes disabled during the first 60 days of continuation coverage, the month that begins more than 30 days after the date he or she is no longer disabled.

  • The maximum allowable time.

    • For terminations (other than for gross misconduct) or reduced hours, 18 months.

    • Other than bankruptcy proceedings for the employer, if another Qualifying Event takes place during the above 18 months, the date which is 36 months after the date of termination or reduced hours.

    • The date of death of the employee or a Qualified Beneficiary who was the surviving spouse of a retired employee; or, in the case of a surviving spouse or dependent children of the employee, 36 months after the employee’s death.

    • For Qualifying Events other than the above situations, 36 months.

    • In the case of termination (other than for gross misconduct) or reduced hours that occurs less than 18 months after the employee becomes entitled to Medicare, the period of coverage for Qualified Beneficiaries (other than the employee) shall be 36 months after the date of Medicare entitlement.

For Qualified Beneficiaries whose period of continuation is expiring under the ”The maximum allowable time,” the plan must, during the 180-day period ending on the expiration date, provide to the beneficiary the option of enrollment under a conversion health plan otherwise generally available under the plan (IRC 4980B(f)(2)(E)).

As one can see, there are many situations that determine the length of time for continuation coverage.

PREMIUMS

Assuming a Qualified Beneficiary chooses to continue insurance coverage, the applicable premium (IRC 4980B(f)(4)(A)) may not exceed 102 percent (IRC 4980B(f)(2)(C)) of the cost for similarly situated beneficiaries to whom a Qualifying Event has not occurred. In other words, the cost for continuation coverage cannot exceed 102 percent of the cost of those in the existing group plan, regardless of who pays the premiums – employee, employer or both.

In some cases, the employer may have chosen to go the self-insured route. In this scenario, the employer does not pay premiums directly to a health insurance company, which assumes the risk, but rather into an employer-controlled fund, which is used for employee claims. Of course, the employer assumes the role of the insurance company to pay claims beyond the fund’s ability to pay. Depending on claims experience, this can be a good thing or real bad thing for the employer and employees.

Anyway, there are special rules that apply to self-insured plans (IRC 4980B(f)(4)(B)). The applicable premium for continuation coverage is a little different than above. It is equal to a “reasonable estimate” of the cost for similarly situated beneficiaries to whom a Qualifying Event has not occurred. This “reasonable estimate” is determined on an actuarial basis and takes into account things that the Secretary of the Treasury may prescribe in regulations. This means that the employer assumes the liability for making the appropriate estimates, which rely upon some person or organization to do actuarial calculations.

There is, however, an exception to the “reasonable estimate” method that the plan administrator can elect to apply, which determines the applicable premium based on past costs and not based on actuarial estimates. In this case, the cost will be the same as for similarly situated beneficiaries for the previous 12-month period, adjusted by the increase or decrease in the implicit price deflator (IPD) of the gross domestic product for a specific time frame. The IPD, which is calculated by the Department of Commerce and published in the Survey of Current Business, is just a method of assigning an inflation ratio to the price changes in the products and services that make up the gross domestic product.

NOTICE REQUIREMENTS

Under this section of COBRA (IRC 4980B(f)(6)), there are various notice requirements depending upon who is affected or what takes place.

1. Upon commencement of group health insurance coverage, the plan administrator shall provide a written notice to each employee and spouse (if applicable) of his or her rights to continuation coverage under COBRA.

2. The employer of an employee must notify the plan administrator of certain Qualifying Events with respect to such employee within 30 days of the date of the Qualifying Event, or within such longer period as some plans may allow. Such events are:

  • The death of the employee.

  • The termination (other than by reason of gross misconduct), or reduction of hours, of the employee.

  • The employee qualifying for Medicare benefits (Title 18 of the Social Security Act).

  • The retired employee’s employer participating in a bankruptcy proceeding.

3. Each employee or Qualified Beneficiary shall notify the plan administrator of certain Qualifying Events with respect to such employee or beneficiary within 60 days after the date of the Qualifying Event. Such events are:

  • The employee divorcing or obtaining a legal separation from his or her spouse.

  • A dependent child no longer a dependent.

4. Each Qualified Beneficiary who is determined, under title 2 or 16 of the Social Security Act, to have been disabled at any time during the first 60 days of continuation coverage shall notify the plan administrator for the following:

  • The determination as to his disability within 60 days after the date of the determination.

  • The final determination that he is no longer disabled within 30 days of the date of the final determination.

5. In the case of any Qualifying Event under #2 above, the plan administrator shall notify any Qualified Beneficiary with respect to such event.

6. In the case of any Qualifying Event under #3 above, the plan administrator shall notify any Qualified Beneficiary with respect to such event the beneficiary’s rights under COBRA.

TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

CHAPTER 2: COBRA Noncompliance
Amount of Tax · Tax Limitations · Who's Liable

Generally, if any group health plan fails to meet the requirements of COBRA with respect to any Qualified Beneficiary, a penalty tax is imposed (IRC 4980B(a)). Of course, there are always exceptions to the general rule (IRC 4980B(d)). Any plan that is a government plan (IRC 414(d)) or church plan (IRC 414(e)) is exempt. Also, any small employer that normally employs fewer than 20 employees on a typical business day throughout the year is exempt.

AMOUNT OF TAX

Generally, the tax imposed for noncompliance shall be $100 for each day of the non-compliance period (IRC 4980B(b)), which is defined as –

  • In the case of one who is liable under “Who’s Liable” below, the beginning date shall not begin before the 45th day after a written request for continuation coverage is received from a Qualified Beneficiary after either of the following Qualifying Events: (1) The employee divorcing or obtaining a legal separation from his or her spouse, or (2) A dependent child no longer a dependent. Otherwise, the beginning date is the date that noncompliance first occurs, and

  • Ending on the earlier of

    • The date noncompliance is corrected, or

    • The date that is six months after the last day under “Period of Coverage” in Chapter 1.

In some instances, the employer (or plan in case of multi-employer plans) will be subject to a minimum tax if noncompliant during an examination process, which follows the issuance of a notice of examination (IRC 4980B(b)(3)). However, if the person responsible for compliance (1) was unaware of any noncompliance while exercising reasonable diligence and (2) corrected the noncompliance within 30 days, no tax will apply. Otherwise, a minimum tax shall apply –

  • If the noncompliance was not corrected before the date a notice of examination of tax liability is sent to the employer, and

  • The noncompliance occurred or continued during the period of examination.

The minimum tax imposed because of failure shall not be less than the lesser of $2,500 or the amount that would have been imposed if the above exceptions to tax did not apply.

A higher penalty will apply if the employer or plan fails a “de minimis” test. Ballentine’s Law Dictionary defines de minimis as: “Of minimal concern” or “concerning insignificant matters.” If this test is failed, then $15,000 shall be substituted for $2,500.

From the above, it appears that any company can avoid tax penalties, or the biggest ones at least, by just exercising some reasonable diligence. The penalty provisions seem to be pretty lax and only meant to provide a corporate incentive to take care of business. However, we all know that even the littlest of things seem to be oftentimes overlooked by responsible persons.

TAX LIMITATIONS

Generally, the amount of tax for a compliance failure shall be $100 per day (IRC 4980B(c)(3)). However, if noncompliance involves more than one Qualified Beneficiary with respect to the same Qualifying Event, the maximum tax shall be $200 per day. This is an overall limitation for failures due to reasonable cause and not willful neglect.

For single employer plans, the tax imposed during the taxable year shall not exceed the lesser of –

  • 10% of the aggregate amount paid or incurred by the employer (or predecessor employer) during the preceding taxable year for group health plans, or

  • $500,000.

For multi-employer plans, the tax imposed during the taxable year shall not exceed the lesser of –

  • 10% of the amount paid or incurred during the taxable year to provide medical care directly or through insurance, reimbursement, or otherwise, or

  • $500,000.

Special Rule (IRC 4980B(c)(4)(C)). “For the actual person who is responsible (other than in the capacity as an employee) for administering or providing benefits under the plan and whose act or failure to act caused a compliance failure, the amount of tax during any taxable year with respect to all plans shall not exceed $2,000,000.” It appears from the wording of this statute that it is geared toward corporate administrators such as third party administrators (TPAs) or such.

Exceptions (IRC 4980B (c)(1) & (2)). No tax shall be imposed if (1) it can be established that the person responsible for compliance did not know, or exercising reasonable diligence could not have known, that noncompliance existed, and (2) the failure was due to reasonable cause and not willful neglect and was corrected within 30 days after the failure became known or should have become known by exercising reasonable diligence.

Waivers (IRC 4980B(c)5)). In the case of a failure that is due to reasonable cause and not willful neglect, the Secretary may waive part or all of the tax imposed to the extent that the payment of such tax would be excessive relative to the failure involved.

Well, we can see again that avoiding tax penalties is easily avoided. Considering the minimum and maximum penalties, it is beyond comprehension as to why any employer would not exercise diligence and avoid undue taxation.

WHO’S LIABLE

Generally, in the case of any group plan that fails COBRA requirements, the following are liable for the tax that is imposed (IRC 4980B(e)(1)):

  • In the case of a plan other than a multi-employer plan, the employer.

  • In the case of a multi-employer plan, the plan.

  • The person who is responsible (other than in the capacity as an employee) for administering or providing benefits under the plan and whose act or failure to act caused (in whole or in part) a compliance failure.

Since being responsible for noncompliance can have grave financial consequences, there are special rules that apply to the last person listed above (IRC 4890B(e)(2)), which is basically a person other than the employer or plan. As with most tax law, a person is not necessarily a living human being, but can also be any entity such as a corporation, trust, business, partnership, etc. That person shall be considered liable for the tax if –

  • That person provided coverage under a group health plan to similarly situated beneficiaries under the plan with respect to whom a Qualifying Event has not occurred, and

  • The employer or plan administrator submits to such person a written request that he make available to a Qualified Beneficiary the same coverage as similarly situated beneficiaries under the plan, or

  • In the case where the person liable is the plan administrator, a Qualified Beneficiary, defined below, submits to such person a written request that he make available to certain Qualified Beneficiaries to whom the following Qualifying Events have occurred the same coverage as similarly situated beneficiaries under the plan to whom the following events have not occurred:

    • The employee divorcing or obtaining a legal separation from his or her spouse.

    • A dependent child no longer a dependent.

TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

CHAPTER 3: Case Analysis

Let’s put all the prior information that we have gathered about COBRA into a simple scenario, for example, a company that wants to implement a group health insurance plan. We’ll choose Summit Widgets, Inc. (SWI) as our company. Where would SWI start and what are some of the questions that need to be asked? A brain storming session would probably establish a need to develop some sort of outline such as the following:

1. Is our company of such a size that makes us subject to COBRA guidelines? If not, do we anticipate such and when?

2. Do we want to be self-insured or use a provider of group health insurance?

3. Should we be part of an established multi-employer plan or should we establish a plan just for our employee’s needs?

4. Who will administer the plan?

5. What procedures do we install to secure compliance?

Even though this is a short list and certainly does not encompass all that a company would want to know, it’s a step in the right direction. As with any brainstorming session or project, one question leads to another question, an answer gives birth to more questions, trial and error produces more options.

Well, the first question is probably the easiest to ascertain. We know that the key number of employees is 20. Let’s summarize IRC 4980B(d) for clarification – “COBRA does not apply to (1) government plans, (2) church plans, or (3) any group health plan that averages fewer than 20 employees during a calendar year.” SWI is a private company; therefore, it is not a government or church organization. If they install their own plan, that is, not part of a larger multi-employer plan, then they will only have to consider their own number of employees. For our example, we’ll assume that they averaged between 25 and 30 employees for the last two years; therefore, SWI will be subject to COBRA.

Next, should they become self-insured or go with an insurance company? Is self-insured something they will want to tackle? Since most companies do not have the expertise, inclination, or financial and people resources to make a legitimate effort to venture in that direction, SWI will choose to contact several local insurance agents to make group health presentations during their next corporate business meeting.

In order to adequately address the third question, they will explore the multi-employer option with the insurance agents. The local economy has a good cross section of service-based and production-based companies. SWI thinks there may be a good fit for them to become part of an established multi-employer group. However, after considering the options shown by the agents, SWI chooses to go out on their own with a single employer plan.

Since SWI is choosing a single employer plan, they are really concerned about the liability issue. IRC 4980B(e) discusses to whom liability falls if a company becomes noncompliant with COBRA. Since they chose not to go with a multi-employer plan, that only leaves two possible entities to assume the role of “person liable,” SWI or a TPA, if so chosen. This brings us to the fourth question because liability, in a manner of speaking, is dependent upon the actions of who administers the plan. In any case of noncompliance with COBRA, SWI will be liable for any penalty tax (IRC 4980B(e)(1)(A)) since they will have a single employer plan. The minimum tax could range from $100 a day up to a minimum of $15,000 and max out at $500,000 or 10% of their annual premium, whichever is less. With those possibilities, SWI will initially choose to go with a TPA who would assume any tax penalty liability for noncompliance issues.

However, by choosing a TPA to administer their group plan, SWI concluded that they would lose part of their ‘control’ factor as well as transferring part of their ‘goodwill,’ which may affect employee moral and public perception. Even though most TPAs are very reliable, SWI thinks that there is too much at risk. Even though the stakes are high, they figure that keeping the administration ‘in-house’ will have more positive results than with a TPA. As with most employers who venture into providing benefits, there is always that unknown factor – some of which can be delegated out and some can’t. When companies reach a comfort zone they can live with and move up the learning curve, then they can always make a change. This seems to be the best solution for SWI at this time.

Since SWI has chosen to administer the plan, we now come to addressing the last question – what procedures do they install in order to secure compliance. Some employee, of course, will have to be delegated the responsibility of becoming SWI’s in-house COBRA expert. If one assumes that the human resource department is typically the area that handles employee and benefits issues, the responsible employee will be out of that area. In this case, it will be Peggy. Her first order of business will be to study everything there is about COBRA as well as create a liaison relationship, assuming one does not already exist, with some sort of legal counsel. Then, she would have to educate staff and employees about all the facets of COBRA that concerns them. This education process can be done (1) initially in group settings when the group health plan is introduced, (2) new employee orientation, and postings throughout the plant. These actions may not guarantee long-term compliance, but doing these things (meetings, reminders, etc.) on a regular basis will keep the message fresh and may, in the minds of the IRS, show that the company did exercise reasonable diligence and will pass the ‘de minimis’ test.

TEST
Table of Contents | Foreword | Introduction
Chapter 1
| Chapter 2 | Chapter 3

TEST

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1. Midwest Widgets, Inc. is a medium sized employer that uses Mideast Administrators to handle its group health plan. Suzy is the human resource manager for Midwest and serves as the company's COBRA expert and liaison to Mideast. Generally, who is liable for any tax imposed because of COBRA noncompliance?

A. Midwest
B. Mideast
C. Suzy
D. All of the above

ABCD

2. Jim's company of 35 is cutting its workforce in half; however, Jim will be retained. In regards to his current group health insurance and COBRA, should he be concerned?

A. Yes, He'll now be covered under a multi-employer plan.
B. No. Since COBRA covers all employers, he'll remain covered.
C. No. Since his company is currently subject to COBRA, he'll continue to be covered after downsizing.
D. Yes. Since the workforce will be less than 20, his company will be exempt from COBRA.

ABCD

3. The IRS determined that ABC Corporation was non compliant with COBRA requirements for 29 days last year in regards to an employee and would be penalized. Since they were not negligent, the IRS will only impute the minimum penalty. What is the amount?

A. $2,500
B. $2,900
C. $3,000
D. $4,500

ABCD

4. For the past 10 years, John has been self-employed and covered under an individual health policy, which did not cover a preexisting non-life-threatening condition that has not manifested itself since he took out the policy. Last week, a large employer with group health benefits hired him. What can he expect from the new group plan?

A. The new health plan will probably deny coverage for his preexisting condition.
B. Group plans will generally cover all preexisting conditions for new employees.
C. COBRA does not require the new employer to provide him coverage.
D. He will probably be denied coverage.

ABCD

5. Seashore Services is a small employer of 20 and has just installed a group health plan. Ron is the manager and responsible for ensuring that the group plan is compliant with all laws. Ron is the manager and responsible for ensuring that the group plan is compliant with all laws. In regards to COBRA, which of the following is not a compliance concern?

A. He must ensure that notice requirements are met.
B. He must ensure that continuation coverage is not inferior to the group plan.
C. He must be diligent in COBRA matters and not negligent.
D. All of the above are compliance concerns.

ABCD

6. Harry and Sue were recently divorced. Both are covered under their employer's group health plan. What COBRA rights does Sue have under Harry's group health plan?

A. She must get a notice from the plan administrator detailing her COBRA rights.
B. She generally has 60 days to make a COBRA election upon a qualifying event.
C. She has no rights.
D. This is not a qualifying event.

ABCD

7. Maria's company went through a reorganization 15 months ago and she was terminated. Since then she has had continuation coverage. Which of the following is not an option for her?

A. She can have continuation coverage for another 21 months.
B. She can get another job that has group health benefits.
C. In 3 months, she can enroll in a conversion health plan.
D. She can enroll in an individual health plan.

ABCD

8. Rocky Mountain Health Management received $6 million in premiums from multiple employers to provide group health benefits to their employees. During the year, they had several infractions of COBRA noncompliance, none of which were due to willful neglect. What is the maximum penalty that the IRS could impose?

A.