Determining COBRA Premiums for Fully Insured and Self-Funded Health Plans

Determining COBRA Premiums for Fully Insured and Self-Funded Health Plans

The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) allows qualified beneficiaries who lose health benefits due to a qualifying event to continue group health benefits. While some group health plans may provide COBRA continuation coverage at a reduced rate or at no cost, most qualified beneficiaries must pay the full COBRA premium. The COBRA election notice should include information about COBRA premiums.
For fully insured health plans, the premium is the cost to maintain the plan for similarly situated employees. For self-funded plans, the premium is the cost to maintain the plan for similarly situated employees as determined by an actuary or the past cost from the preceding determination period. The applicable premium calculation for both fully- and self-funded plans includes the cost of providing coverage to both active employees and COBRA qualified beneficiaries. All COBRA premiums must be calculated in good faith compliance with a reasonable interpretation of COBRA requirements.
Generally, COBRA payments are made on an after-tax basis. Qualified beneficiaries have 45 days after the election date to make an initial premium payment. The plan may terminate the qualified beneficiary’s COBRA rights if no initial premium payment is made before the end of the 45-day period. In addition, plans must allow monthly premium payments and cannot require payment on a quarterly basis. As established under COBRA, premiums are due on the first day of each month with a minimum 30-day grace period. A plan may terminate COBRA coverage for nonpayment or insufficient payment of premiums after the grace period.
If a qualified beneficiary makes an insignificant underpayment, then the premium payment will still satisfy the payment obligation. An underpayment is deemed insignificant if the shortfall is no greater than the lesser of $50 or 10 percent of the required amount. However, if the plan notifies the qualified beneficiary of the shortfall and grants a reasonable amount of time to correct the underpayment (usually 30 days after the notice is provided), then the qualified beneficiary is required to make the payment; otherwise, COBRA coverage may be canceled.
Fully Insured Health Plans
Generally, the applicable COBRA premium amount for fully insured plans is the insurance premium charged by the insurer. The applicable premium is based on the total cost of coverage, which includes both the employer and employee portions. The premium amount is based on the cost of coverage for similarly situated individuals who have not incurred a qualifying event.
A group health plan may charge at most 102 percent of the premium during the standard COBRA coverage period for similarly situated plan participants (100 percent of the total cost of coverage plus an additional 2 percent for administrative costs). However, the plan may increase the premium for a disabled qualified beneficiary and charge 150 percent of the applicable premium during the 11-month disability extension period (months 19 through 29). In addition, COBRA regulations permit a plan to charge a 150 percent premium to nondisabled qualified beneficiaries as long as the disabled qualified beneficiary is covered under the plan. If the disabled qualified beneficiary is no longer covered under the plan, then the remaining qualified beneficiaries may continue coverage up to 29 months at 102 percent of the cost of the plan.
If an employer maintains more than one plan, then a separate applicable premium is calculated for each plan. Also, the applicable premium for a single plan may vary due to factors such as the coverage level, the benefit package, and the region in which covered employee resides. For instance, single employees may pay a different applicable premium than employees who include their spouse on the plan. Thus, the plan may charge different premiums based on the varying coverage levels.
The most common tier structures include employee-only, employee-plus-spouse, employee-plus-children, and employee-plus-family. According to Internal Revenue Ruling 96-8, a fully insured plan that pays different premiums for individual versus family coverage must use those same premium tiers for COBRA continuation coverage. Thus, COBRA premiums are divided into multi-rate and single-rate tier structures.
By Danielle Capilla
Originally Published By United Benefit Advisors

When Grief Comes to Work

When Grief Comes to Work

Death and loss touch all of us, usually many times throughout our lives. Yet we may feel unprepared and uncomfortable when grief intrudes into our daily routines. As a manager, when grief impacts your employees it’s helpful to have a basic understanding of what they are going through as well as ways you can help.
Experiencing Grief
Although we all experience grief in our own way, there are behaviors, emotions and physical sensations that are a common part of the mourning process. J. William Worden’s “Four Tasks of Mourning” will be experienced in some form by anyone who is grieving. These tasks include accepting the reality of the loss, experiencing and accepting our emotions, adjusting to life without the loved one, and investing emotional energy into a new and different life.
Commonly experienced emotions are sadness, anger, frustration, guilt, shock and numbness. Physical sensations include fatigue or weakness, shortness of breath, tightness in the chest and dry mouth.
Manager’s Role
When employees are mourning, it’s important to create a caring, supportive and professional work environment. In most cases, employees will benefit from returning to work. It allows them to resume a regular routine, focus on something besides their loss and boost their confidence by completing work tasks.
At the same time, bereaved employees may experience many challenges when returning to work. They may have poor concentration, be extremely tired, feel depressed or have a short temper and uncontrollable emotions.
As a manager, the best thing you can do is acknowledge the loss and maintain strong lines of communication. Even if you believe someone else is checking in with them, make sure you stay in touch and see if there is anything you can do.
Developing a Return to Work Plan
In order to help your employees have a smooth transition back to work you must listen and understand their needs. Some additional questions you’ll want to answer are:

  • What are your company’s policies and procedures for medical and bereavement leave?
  • What information do your employees want their co-workers to have and would they rather share this information themselves?
  • Do they want to talk about their experience or would they rather focus on work?
  • Do they need private time while at work?
  • Does their workload and schedule need to be adjusted?
  • Do they need help at home – child care, meals, house work, etc.?
  • Are there others at work that may be experiencing grief of their own?

Helpful Responses for Managers

  • Offer specific help – make meals, wash their car, walk their pet, or anything else that will make their life easier.
  • Say something – it can be as simple as, “I’m so sorry for your loss.”
  • Listen – be kind but honest.
  • Respect privacy – honor closed doors and private moments.
  • Expect tears – emotions can hit unexpectedly.
  • Thank your staff – for everything they are doing to help.

Grieving is a necessity, not a weakness. It is how we heal and move forward. As a manager, being there for your employees during this time is important in helping them through the grieving process.
An Employee Assistance Program is a great resource for both you and your employees when grief comes to work.
By Kathyrn Schneider
Originally Posted By www.ubabenefits.com

Best Practices for Initial COBRA Notices

Best Practices for Initial COBRA Notices

The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) requires group health plans to provide notices to covered employees and their families explaining their COBRA rights when certain events occur. The initial notice, also referred to as the general notice, communicates general COBRA rights and obligations to each covered employee (and his or her spouse) who becomes covered under the group health plan. This notice is issued by the plan administrator within the first 90 days when coverage begins under the group health plan and informs the covered employee (and his or her spouse) of the responsibility to notify the employer within 60 days if certain qualifying events occur in the future.
The initial notice must include the following information:

  • The plan administrator’s contact information
  • A general description of the continuation coverage under the plan
  • An explanation of the covered employee’s notice obligations, including notice of
    • The qualifying events of divorce, legal separation, or a dependent’s ceasing to be a dependent
    • The occurrence of a second qualifying event
    • A qualified beneficiary’s disability (or cessation of disability) for purposes of the disability extension)
  • How to notify the plan administrator about a qualifying event
  • A statement that the notice does not fully describe continuation coverage or other rights under the plan, and that more complete information regarding such rights is available from the plan administrator and in the plan’s summary plan description (SPD)

As a best practice, the initial notice should also:

  • Direct qualified beneficiaries to the plan’s most recent SPD for current information regarding the plan administrator’s contact information.
  • For plans that include health flexible spending arrangements (FSAs), disclose the limited nature of the health FSA’s COBRA obligations (because certain health FSAs are only obligated to offer COBRA through the end of the year to qualified beneficiaries who have underspent accounts).
  • Explain that the spouse may notify the plan administrator within 60 days after the entry of divorce or legal separation (even if an employee reduced or eliminated the spouse’s coverage in anticipation of the divorce or legal separation) to elect up to 36 months of COBRA coverage from the date of the divorce or legal separation.
  • Define qualified beneficiary to include a child born to or placed for adoption with the covered employee during a period of COBRA continuation coverage.
  • Describe that a covered child enrolled in the plan pursuant to a qualified medical child support order during the employee’s employment is entitled to the same COBRA rights as if the child were the employee’s dependent child.
  • Clarify the consequences of failing to submit a timely qualifying event notice, timely second qualifying event notice, or timely disability determination notice.

Practically speaking, the initial notice requirement can be satisfied by including the general notice in the group health plan’s SPD and then issuing the SPD to the employee and his or her spouse within 90 days of their group health plan coverage start date.
If the plan doesn’t rely on the SPD for furnishing the initial COBRA notice, then the plan administrator would follow the U.S. Department of Labor (DOL) rules for delivery of ERISA-required items. A single notice addressed to the covered employee and his or her spouse is allowed if the spouse lives at the same address as the covered employee and coverage for both the covered employee and spouse started at the time that notice was provided. The plan administrator is not required to provide an initial notice for dependents.
By Danielle Capilla
Originally Posted By www.ubabenefits.com

How to Be a Magnetic Organization

How to Be a Magnetic Organization

When we hear something’s magnetic, it’s likely the first thought that comes to mind is attraction. By definition, a magnetic force is the attraction or repulsion that arises between electrically charged particles because of their motion. What perfect framing for an organization – the desire to attract (or repel) people to help advance your organization. With this framing comes the assumption that there’s motion, which is, hopefully, a result of intentional action.
If we follow the thought of intentional action, there are seven steps (and many more details for each step that would be too lengthy to include here) that attract what’s desired and repel what’s not desired.
Seven Steps to Being a Magnetic Organization
1.  Decide what you want for the company
Simple, right? Yes. However, often an assumption is made that everybody knows what’s wanted. The best way to determine if you know what’s wanted is to ask the question, “Can I paint a clear, colorful and compelling story of the future?” This is one of the most important roles of leadership in an organization. Create, and tell a compelling story worthy of the effort it will take to get there.
2.  Get 100 percent buy-in from top leadership
It’s not enough for the CEO or owner to own the future story, every top leader who’s responsible for the performance and experience of employees and customers needs to be 100 percent committed to the future. This is perhaps the most telling test of how quickly and assuredly you will achieve the goals to support the future state. It’s critical to check for this buy-in up front as well as at key milestone points along the way.
3.  Communicate
As important as the first two steps are, a pinnacle point in the process is sharing with your employees, customers, and other stakeholders what you intend to do.
This is a step that is often overlooked and undervalued. If you ascribe to the rule of seven for marketing, it takes at least seven exposures for a person to hear something with the likelihood of remembering the message. Communicate often and keep your message clear and consistent. Also, keep in mind that people absorb information differently. This absorption is relative to learning styles. Presenting information will be accepted differently if someone is visual, aural, verbal, physical, logical, social, or solitary in their learning style.
As you design your communication plan, explore not only what you’ll share, but how you’ll promote the messages.
4.  Build Your Culture
This speaks to the actions necessary to achieve desired outcomes. It’s intentionally ordered after communication. Reinforce the mission of the company, or roll it out if it’s newly created. To move forward, you need every employee to be aware of the direction and expectations for the organization. Share organizational goals and keep leaders accountable to create alignment for their teams, including working with each person on their team to understand how his or her unique role fits into the overall picture. This will drive interactions that contribute to, or detract from, success.
Involve employees in the early phases of culture change and share quick wins. Consider including stories and testimonials from employees that show how the company is already making strides to get to the future vision.
Assure the right fit of employees. Clearly identify the top three expectations for each role and then find people who will be on fire to do these things well.
David Pink, in his book Drive, explores exactly what motivates people and claims that true motivation consists of: 1) autonomy, the desire to direct our own lives; 2) mastery, the desire to continually improve at something that matters; and 3) purpose, the desire to do things in service of something larger than ourselves.
In addition, make a habit of catching people doing the right things right. Recognition of work well done continuously reinforced will add fuel to building a positive culture. Finally, allow people to be who they are and find ways to insert moments of fun.
5.  Evaluate
There are many evaluation tools to help identify what’s happening. Asking for feedback from employees and customers can be a highly effective way to help understand where the best practices exist and where improvements are needed. Measuring what’s happening on a regular basis offers identification of value in processes and with products.
According to the Predictions for 2017 Bersin by Deloitte report, “Driven by the need to understand and improve engagement, and the continuous need to measure and improve employee productivity, real time feedback and analytics will explode.”
6.  Assess
The intention of assessment is to determine how things are going and then focus on improvement. The people who know the operations the best are the ones working the business. Trust your employees. As you understand the frustrations and barriers employees encounter, there’s an opportunity to reengineer how to tailor processes, deliver services, and provide products to support the changing needs of the customer.
7.  Adjust
When you identify what’s working and what needs to be changed – act with a sense of urgency to make the necessary changes. The organizations who adapt are the ones who have the greatest longevity. Market changes are constant and the ability to understand what’s happening and move toward what will occur in the future is not only admirable, but necessary for sustainability.
It’s obvious how these steps attract people with desired talents and attitudes to help advance your organization, but how will these same actions repel those who don’t align? When there’s consistent reinforcement of the culture, those who don’t fit will have a sense that your company just isn’t the right place for them, like trying to fit into a jacket that is too small or too large. This will be true for current employees and potential employees.
Not getting the results you want? Consider revisiting these actions – one step at a time.

By Joan Morehead
Originally Posted By www.ubabenefits.com

Strategic Benefits Communication: Leverage Technology, But Keep It Personal – Part Four of a Five-Part Series

Strategic Benefits Communication: Leverage Technology, But Keep It Personal – Part Four of a Five-Part Series

Many employers have invested in benefits administration systems to streamline their processes and connectivity with payroll systems as well as external vendors. From an efficiency and reporting perspective, this works wonderfully. However, when it comes to leveraging that technology for open enrollment and benefits communication, there can be gaps that limit effectiveness.
Our recent survey found that while technology plays a big role (47 percent of surveyed employees used a platform to enroll in their benefits), only 15 percent used an online tool to learn about their options. The good news is that of those who sought information, 90 percent found that interactive digital experience to be helpful.
The question then is, how do we encourage employees to seek information about the benefits available to them?
In a previous blog post, we talked about the power of personalization. Employees want the ability to customize their benefits package to meet their needs. This can seem challenging if your enrollment experience is limited to a simple (or overly complex) menu of benefits, only accompanied by the ability to elect participate, or waive (some may include links to product information). From a data perspective, this can be a seamless HR experience—but is it a great experience for employees?
There are several ways to create a better employee experience and your UBA advisors and vendor partners can help.
When you are planning your next open enrollment, ask your benefits administration partner what, if any, benefits communication tools they may have. Some platforms have started to incorporate dynamic video and animated presentations that help personalize the enrollment experience. Highlight these tools to your employees as part of the pre-enrollment communication package.
Insurance providers and other vendors are also great resources. Insurers may have product calculators to help employees determine coverage amounts that make sense for them. They may also have videos as well as single sign-on links that provide employees additional information. The same types of tools may be available from other vendors, such as health savings account (HSA) administrators.
Consider one-to-one employee meetings with a benefits counselor. Eighty-six percent of surveyed employees said they want a clearer explanation of benefits choices, and 80 percent want one-on-one time. Remember, your employees learn differently, and many could benefit from having a personal conversation about their needs. In many cases, it is possible to work with a carrier, or vendor, that can actually conduct the meetings and enroll employees on the benefits administration platform. The one-on-one meetings help employees learn about options specific to their circumstances, and the on-site representative can help guide them on how to use the system. This can also be an opportunity to update employee information such as dependents, beneficiaries, and contact information.
Successfully blending personalized benefits communication strategies with benefits administration technology can help increase employee engagement and streamline your processes.
By Kevin D. Seeker
Originally Posted By www.ubabenefits.com

A Country Polarized? Make Sure Your Office Isn’t

A Country Polarized? Make Sure Your Office Isn’t

One of the latest things trending right now in business is the importance of office culture. When everyone in the office is working well together, productivity rises and efficiency increases. Naturally, the opposite is true when employees do not work well together and the corporate culture suffers. So, what are these barriers and what can you do to avoid them?
According to an article titled, “8 ways to ruin an office culture,” in Employee Benefit News, the ways to kill corporate culture may seem intuitive, but that doesn’t mean they still don’t happen. Here’s what organizations SHOULD do to improve their corporate culture.
Provide positive employee feedback. While it’s easy to criticize, and pointing out employees’ mistakes can often help them learn to not repeat them, it’s just as important to recognize success and praise an employee for a job well done. An “attaboy/attagirl” can really boost someone’s spirits and let them know their work is appreciated.
Give credit where credit is due. If an assistant had the bright idea, if a subordinate did all the work, or if a consultant discovered the solution to a problem, then he or she should be publicly acknowledged for it. It doesn’t matter who supervised these people, to the victor go the spoils. If someone had the guts to speak up, then he or she should get the glory. Theft is wrong, and it’s just as wrong when you take someone’s idea, or hard work, and claim it as your own.
Similarly, listen to all ideas from all levels within the company. Every employee, regardless of their position on the corporate ladder, likes to feel that their contributions matter. From the C-suite, all the way down to the interns, a genuinely good idea is always worth investigating regardless of whether the person who submitted the idea has an Ivy League degree or not. Furthermore, sometimes it takes a different perspective – like one from an employee on a different management/subordinate level – to see the best way to resolve an issue.
Foster teamwork because many hands make light work. Or, as I like to say, competition breeds contempt. You compete to get your job, you compete externally against other companies, and you may even compete against your peers for an award. You shouldn’t have to compete with your own co-workers. The winner of that competition may not necessarily be the best person and it will often have negative consequences in terms of trust.
Get rid of unproductive employees. One way to stifle innovation and hurt morale is by having an employee who doesn’t do any work while everyone else is either picking up the slack, or covering for that person’s duties. Sometimes it’s necessary to prune the branches.
Let employees have their privacy – especially on social media. As long as an employee isn’t conducting personal business on company time, there shouldn’t be anything wrong with an employee updating their social media accounts when they’re “off the clock.” In addition, as long as employees aren’t divulging company secrets, or providing other corporate commentary that runs afoul of local, state, or federal laws, then there’s no reason to monitor what they post.
Promote a healthy work-life balance. Yes, employees have families, they get sick, or they just need time away from the workplace to de-stress. And while there will always be times when extra hours are needed to finish a project, it shouldn’t be standard operating procedure at a company to insist that employees sacrifice their time.
By Geoff Mukhtar
Originally Posted By www.ubabenefits.com