The document provides information about changes to COBRA coverage and subsidies under the American Recovery and Reinvestment Act of 2009. It summarizes that the Act provides a 65% government subsidy for COBRA health coverage for qualified individuals for up to 9 months. It outlines eligibility criteria for the subsidy and requirements for employers, such as providing notices about the availability of the subsidy to eligible former employees. Employers can receive reimbursement of subsidies paid through reductions in their federal payroll taxes.
This document discusses a recent court case where a reinsurer was found not to be bound by a stipulation between an employer and employee in a workers' compensation case. The stipulation set the date of injury, but the court found the reinsurer could determine the date of injury using a different section of the labor code. This adds challenges for self-insured employers seeking reimbursement from reinsurers. It recommends employers increase training, monitor disease claims management, independently review potential stipulations, consider joining reinsurers to WCAB proceedings, and develop new strategies to address post-WCAB implications on reinsurance recovery.
This document summarizes new provisions related to COBRA health insurance coverage included in the American Recovery and Reinvestment Act of 2009 stimulus package. It discusses that employees involuntarily terminated between September 2008 and December 2009, and their families, will only have to pay 35% of premiums for up to 9 months of continued coverage, with employers reimbursed for the remaining 65% through tax credits. It also outlines requirements for employers to provide updated notices to qualified beneficiaries about their options by April 18, 2009.
Captive insurance companies (CICs) provide significant benefits to businesses. CICs allow businesses to customize their insurance plans to better match their specific risks and needs. They also provide tax benefits as premiums paid to a CIC are fully tax deductible. Additionally, CICs can elect to receive up to $1.2 million in insurance premium income tax-free each year. Finally, CICs can be structured to provide estate planning benefits by transferring the value of the CIC to descendants without gift, estate or generation-skipping transfer taxes. In summary, CICs provide customized insurance coverage, tax benefits, and potential estate planning advantages for businesses.
"Top 10 Business Law Cases of the Year" (2019)Wendy Couture
The document summarizes key cases relating to business law from the past year. It discusses Greenwald v. Western Surety Co., which addressed whether losses sustained by a business owner through the dishonest acts of his financial manager were covered by a fidelity bond. It also discusses Oxbow Carbon & Minerals Holdings, Inc. v. Crestview-Oxbow Acquisition, LLC, which involved an LLC agreement that created a "gap" regarding the rights of new members and whether an "implied covenant of good faith and fair dealing" could supply the missing term.
The document summarizes the provisions of the American Recovery and Reinvestment Act of 2009 relating to COBRA health insurance subsidies. It provides details on eligibility requirements, the 65% premium subsidy for qualified beneficiaries, additional notice requirements, and immediate compliance actions needed by employers. Key points include a subsidy for up to 9 months of COBRA coverage for involuntarily terminated individuals, additional notices that must be sent by March 19, 2009, and ensuring COBRA administration can properly process subsidies and payroll tax credits.
This short document outlines an experiment but provides little details, mentioning a problem, equipment needed, and an experiment menu but without describing them. It concludes abruptly.
This short document outlines an experiment but provides little details, mentioning a problem, equipment needed, and an experiment menu but without describing them. It concludes abruptly.
This document discusses a recent court case where a reinsurer was found not to be bound by a stipulation between an employer and employee in a workers' compensation case. The stipulation set the date of injury, but the court found the reinsurer could determine the date of injury using a different section of the labor code. This adds challenges for self-insured employers seeking reimbursement from reinsurers. It recommends employers increase training, monitor disease claims management, independently review potential stipulations, consider joining reinsurers to WCAB proceedings, and develop new strategies to address post-WCAB implications on reinsurance recovery.
This document summarizes new provisions related to COBRA health insurance coverage included in the American Recovery and Reinvestment Act of 2009 stimulus package. It discusses that employees involuntarily terminated between September 2008 and December 2009, and their families, will only have to pay 35% of premiums for up to 9 months of continued coverage, with employers reimbursed for the remaining 65% through tax credits. It also outlines requirements for employers to provide updated notices to qualified beneficiaries about their options by April 18, 2009.
Captive insurance companies (CICs) provide significant benefits to businesses. CICs allow businesses to customize their insurance plans to better match their specific risks and needs. They also provide tax benefits as premiums paid to a CIC are fully tax deductible. Additionally, CICs can elect to receive up to $1.2 million in insurance premium income tax-free each year. Finally, CICs can be structured to provide estate planning benefits by transferring the value of the CIC to descendants without gift, estate or generation-skipping transfer taxes. In summary, CICs provide customized insurance coverage, tax benefits, and potential estate planning advantages for businesses.
"Top 10 Business Law Cases of the Year" (2019)Wendy Couture
The document summarizes key cases relating to business law from the past year. It discusses Greenwald v. Western Surety Co., which addressed whether losses sustained by a business owner through the dishonest acts of his financial manager were covered by a fidelity bond. It also discusses Oxbow Carbon & Minerals Holdings, Inc. v. Crestview-Oxbow Acquisition, LLC, which involved an LLC agreement that created a "gap" regarding the rights of new members and whether an "implied covenant of good faith and fair dealing" could supply the missing term.
The document summarizes the provisions of the American Recovery and Reinvestment Act of 2009 relating to COBRA health insurance subsidies. It provides details on eligibility requirements, the 65% premium subsidy for qualified beneficiaries, additional notice requirements, and immediate compliance actions needed by employers. Key points include a subsidy for up to 9 months of COBRA coverage for involuntarily terminated individuals, additional notices that must be sent by March 19, 2009, and ensuring COBRA administration can properly process subsidies and payroll tax credits.
This short document outlines an experiment but provides little details, mentioning a problem, equipment needed, and an experiment menu but without describing them. It concludes abruptly.
This short document outlines an experiment but provides little details, mentioning a problem, equipment needed, and an experiment menu but without describing them. It concludes abruptly.
The American Recovery and Reinvestment Act of 2009 provides a subsidy of 65% of COBRA premiums for involuntarily terminated employees for up to 9 months. Eligible individuals include those terminated between September 1, 2008 and December 31, 2009. Employers must provide retroactive notice by April 19, 2009 to all terminated employees from September 1, 2008 onward about their potential COBRA subsidy eligibility. Employers can recoup the 65% subsidy amount through payroll tax credits.
This document provides an overview of the nuts and bolts of COBRA. It discusses what COBRA is, who it applies to, qualifying events, qualified beneficiaries, required notices, costs, length of coverage, termination of coverage, penalties for non-compliance, and common mistakes made with COBRA. It aims to explain the key aspects of administering and complying with COBRA requirements for employers.
CBC Mortgage Agency (CBCMA) is a federally chartered, public-purpose government lender. CBC Mortgage Agency (CBCMA) created Chenoa Fund to help lenders to assist their borrowers to obtain the 3.5% minimum required investment on an FHA loan.
The document summarizes provisions of the American Recovery and Reinvestment Act of 2009 regarding subsidies for COBRA health insurance premiums. It provides details on eligibility requirements, the amount of subsidies, how subsidies are administered and reimbursed, notification requirements, and income limits for receiving subsidies. The key points are that the Act provides subsidies of 65% of COBRA premiums for involuntarily terminated workers for up to 9 months, subsidies are claimed as a tax credit by employers/plans, and certain income thresholds apply for subsidy eligibility.
CBC Mortgage Agency (CBCMA) is a federally chartered, public-purpose government lender. CBC Mortgage Agency (CBCMA) created Chenoa Fund to help lenders to assist their borrowers to obtain the 3.5% minimum required investment on an FHA loan.
The document provides additional questions and answers from the IRS regarding the COBRA premium assistance provisions. Key points covered include: 1) employers have flexibility in determining if a termination was involuntary; 2) seasonal and temporary workers whose contracts expire can be considered involuntary terminations; 3) reserve and National Guard duty is an involuntary termination regardless of leave status; and 4) individuals have flexibility in choosing the effective date of their COBRA coverage within limits of the subsidy period.
1.C Conventional Chenoa Fund Programs OverviewChenoa Fund
This training series covers Chenoa Fund down payment assistance programs, including conventional and FHA loans. It includes sessions on program overviews, income calculations, the URLA, underwriting, locking loans, securing down payment assistance, document drawing, purchase clearing conditions, final documents, servicing, and why to use Chenoa Fund programs. The document matrix provides a quick comparison of the Conventional Standard 97% LTV Loans and Fannie Mae HomeReady® programs.
Check the various FAQs answers here about the implementation of the Paycheck Protection Program (PPP) Loans, established by section 1102 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act). CARES Act is the largest economic relief bill in United States history which will support individuals and businesses affected by the COVID-19 pandemic.
COBRA provides temporary continuation of health coverage when it would otherwise be lost due to certain events like job loss. It applies to employers with 20+ employees and provides qualified beneficiaries like employees, spouses, dependents up to 36 months of continued coverage at group rates. When coverage is lost due to job loss, reduction in hours, divorce or other qualifying events, beneficiaries must be notified of COBRA rights and have 60 days to elect continued coverage by paying premiums. Coverage can end earlier for non-payment of premiums or obtaining other coverage, and conversion to individual policies must be offered at the end of the continuation period.
This document provides an overview and summary of a training on Chenoa Fund programs offered by CBC Mortgage Agency. The training covers all aspects of the programs from initial registration to final documents. It includes summaries of the Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loan programs. Key details like qualifying criteria, terms, and documentation requirements are highlighted for each program. The document also reviews topics like underwriting, the funding obligation letter, homebuyer education, and undisclosed debt monitoring.
The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) requires that employers provide former employees and dependents who lose group health benefits with an opportunity to continue group health insurance coverage for a limited period of time. Compliance with the complex rules regarding COBRA coverage can be difficult and mistakes can be costly. Penalties for non-compliance can include IRS excise taxes and ERISA statutory fines.
This Legislative Brief provides practical information and tips for avoiding these penalties and other risks, such as lawsuits to compel coverage and adverse selection of COBRA coverage.
AIG was contractually obligated to pay about $165 million in retention pay to AIGFP employees according to a 2008 retention plan. About $55 million had already been paid in December 2008. AIG was also obligated to pay $6 million in guaranteed pay outside the plan. Failing to make the legally required retention payments could result in AIG owing double damages plus penalties, and risked significant business and legal issues due to the complexity of AIGFP's derivatives portfolio.
1.F FHA Chenoa Fund Programs Overview (v9.2)Chenoa Fund
This document provides an overview and summary of Chenoa Fund training programs, including:
- A list of 13 training topics covering Chenoa Fund programs, underwriting, locks, documents, and servicing.
- General information about Chenoa Fund programs, including that they are DPA products offered in all states except New York, with 3.5% offered for the second mortgage.
- Summaries of the Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loan programs, including details on qualifying income limits, credit score requirements, terms, and more.
The Credit Card Accountability Responsibility and Disclosure Act of 2009 or Credit CARD Act of 2009 is a federal law passed by the United States Congress
1.f (v8.2) fha chenoa fund programs overviewChenoa Fund
This document provides an overview and summary of Chenoa Fund training programs offered by CBC Mortgage Agency. The training includes 13 modules covering various topics related to Chenoa Fund programs including: program overviews, income calculations, registration, underwriting, locking loans, document preparation, and servicing. It also summarizes key details of CBCMA's FHA down payment assistance programs including Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second. Details provided for each program include eligible property types, minimum credit scores, income limits, DTI requirements, loan terms, and other guidelines.
1.f (v8.3) fha chenoa fund programs overviewChenoa Fund
This training covers Chenoa Fund programs including conventional and FHA loans. It provides overviews of program guidelines for Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loans. Key details covered include eligible property types, minimum credit scores, income limits, DTI requirements, terms of the secondary financing, and alternative qualification options. The training also addresses topics like funding obligation letters, fees, and homebuyer education requirements.
This training series covers Chenoa Fund down payment assistance programs, including an overview of conventional and FHA programs, how to calculate AMI, the URLA registration process, underwriting, locking loans, securing DPA approvals, document preparation, purchase clearing conditions, final documents, servicing, and why to use Chenoa Fund programs. Specific programs covered include Rate Advantage (FHA), DPA Edge: Repayable Second (FHA), DPA Edge: Soft Second (FHA), Conventional Standard 97% LTV Loans, and HomeReady® (Conventional). The training also reviews FHA homebuyer education requirements, verification of housing expense documentation, and alternative qualification options for borrowers with credit scores between 640
SATTA MATKA SATTA FAST RESULT KALYAN TOP MATKA RESULT KALYAN SATTA MATKA FAST RESULT MILAN RATAN RAJDHANI MAIN BAZAR MATKA FAST TIPS RESULT MATKA CHART JODI CHART PANEL CHART FREE FIX GAME SATTAMATKA ! MATKA MOBI SATTA 143 spboss.in TOP NO1 RESULT FULL RATE MATKA ONLINE GAME PLAY BY APP SPBOSS
The Steadfast and Reliable Bull: Taurus Zodiac Signmy Pandit
Explore the steadfast and reliable nature of the Taurus Zodiac Sign. Discover the personality traits, key dates, and horoscope insights that define the determined and practical Taurus, and learn how their grounded nature makes them the anchor of the zodiac.
The American Recovery and Reinvestment Act of 2009 provides a subsidy of 65% of COBRA premiums for involuntarily terminated employees for up to 9 months. Eligible individuals include those terminated between September 1, 2008 and December 31, 2009. Employers must provide retroactive notice by April 19, 2009 to all terminated employees from September 1, 2008 onward about their potential COBRA subsidy eligibility. Employers can recoup the 65% subsidy amount through payroll tax credits.
This document provides an overview of the nuts and bolts of COBRA. It discusses what COBRA is, who it applies to, qualifying events, qualified beneficiaries, required notices, costs, length of coverage, termination of coverage, penalties for non-compliance, and common mistakes made with COBRA. It aims to explain the key aspects of administering and complying with COBRA requirements for employers.
CBC Mortgage Agency (CBCMA) is a federally chartered, public-purpose government lender. CBC Mortgage Agency (CBCMA) created Chenoa Fund to help lenders to assist their borrowers to obtain the 3.5% minimum required investment on an FHA loan.
The document summarizes provisions of the American Recovery and Reinvestment Act of 2009 regarding subsidies for COBRA health insurance premiums. It provides details on eligibility requirements, the amount of subsidies, how subsidies are administered and reimbursed, notification requirements, and income limits for receiving subsidies. The key points are that the Act provides subsidies of 65% of COBRA premiums for involuntarily terminated workers for up to 9 months, subsidies are claimed as a tax credit by employers/plans, and certain income thresholds apply for subsidy eligibility.
CBC Mortgage Agency (CBCMA) is a federally chartered, public-purpose government lender. CBC Mortgage Agency (CBCMA) created Chenoa Fund to help lenders to assist their borrowers to obtain the 3.5% minimum required investment on an FHA loan.
The document provides additional questions and answers from the IRS regarding the COBRA premium assistance provisions. Key points covered include: 1) employers have flexibility in determining if a termination was involuntary; 2) seasonal and temporary workers whose contracts expire can be considered involuntary terminations; 3) reserve and National Guard duty is an involuntary termination regardless of leave status; and 4) individuals have flexibility in choosing the effective date of their COBRA coverage within limits of the subsidy period.
1.C Conventional Chenoa Fund Programs OverviewChenoa Fund
This training series covers Chenoa Fund down payment assistance programs, including conventional and FHA loans. It includes sessions on program overviews, income calculations, the URLA, underwriting, locking loans, securing down payment assistance, document drawing, purchase clearing conditions, final documents, servicing, and why to use Chenoa Fund programs. The document matrix provides a quick comparison of the Conventional Standard 97% LTV Loans and Fannie Mae HomeReady® programs.
Check the various FAQs answers here about the implementation of the Paycheck Protection Program (PPP) Loans, established by section 1102 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act). CARES Act is the largest economic relief bill in United States history which will support individuals and businesses affected by the COVID-19 pandemic.
COBRA provides temporary continuation of health coverage when it would otherwise be lost due to certain events like job loss. It applies to employers with 20+ employees and provides qualified beneficiaries like employees, spouses, dependents up to 36 months of continued coverage at group rates. When coverage is lost due to job loss, reduction in hours, divorce or other qualifying events, beneficiaries must be notified of COBRA rights and have 60 days to elect continued coverage by paying premiums. Coverage can end earlier for non-payment of premiums or obtaining other coverage, and conversion to individual policies must be offered at the end of the continuation period.
This document provides an overview and summary of a training on Chenoa Fund programs offered by CBC Mortgage Agency. The training covers all aspects of the programs from initial registration to final documents. It includes summaries of the Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loan programs. Key details like qualifying criteria, terms, and documentation requirements are highlighted for each program. The document also reviews topics like underwriting, the funding obligation letter, homebuyer education, and undisclosed debt monitoring.
The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) requires that employers provide former employees and dependents who lose group health benefits with an opportunity to continue group health insurance coverage for a limited period of time. Compliance with the complex rules regarding COBRA coverage can be difficult and mistakes can be costly. Penalties for non-compliance can include IRS excise taxes and ERISA statutory fines.
This Legislative Brief provides practical information and tips for avoiding these penalties and other risks, such as lawsuits to compel coverage and adverse selection of COBRA coverage.
AIG was contractually obligated to pay about $165 million in retention pay to AIGFP employees according to a 2008 retention plan. About $55 million had already been paid in December 2008. AIG was also obligated to pay $6 million in guaranteed pay outside the plan. Failing to make the legally required retention payments could result in AIG owing double damages plus penalties, and risked significant business and legal issues due to the complexity of AIGFP's derivatives portfolio.
1.F FHA Chenoa Fund Programs Overview (v9.2)Chenoa Fund
This document provides an overview and summary of Chenoa Fund training programs, including:
- A list of 13 training topics covering Chenoa Fund programs, underwriting, locks, documents, and servicing.
- General information about Chenoa Fund programs, including that they are DPA products offered in all states except New York, with 3.5% offered for the second mortgage.
- Summaries of the Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loan programs, including details on qualifying income limits, credit score requirements, terms, and more.
The Credit Card Accountability Responsibility and Disclosure Act of 2009 or Credit CARD Act of 2009 is a federal law passed by the United States Congress
1.f (v8.2) fha chenoa fund programs overviewChenoa Fund
This document provides an overview and summary of Chenoa Fund training programs offered by CBC Mortgage Agency. The training includes 13 modules covering various topics related to Chenoa Fund programs including: program overviews, income calculations, registration, underwriting, locking loans, document preparation, and servicing. It also summarizes key details of CBCMA's FHA down payment assistance programs including Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second. Details provided for each program include eligible property types, minimum credit scores, income limits, DTI requirements, loan terms, and other guidelines.
1.f (v8.3) fha chenoa fund programs overviewChenoa Fund
This training covers Chenoa Fund programs including conventional and FHA loans. It provides overviews of program guidelines for Rate Advantage, DPA Edge Repayable Second, and DPA Edge Soft Second FHA loans. Key details covered include eligible property types, minimum credit scores, income limits, DTI requirements, terms of the secondary financing, and alternative qualification options. The training also addresses topics like funding obligation letters, fees, and homebuyer education requirements.
This training series covers Chenoa Fund down payment assistance programs, including an overview of conventional and FHA programs, how to calculate AMI, the URLA registration process, underwriting, locking loans, securing DPA approvals, document preparation, purchase clearing conditions, final documents, servicing, and why to use Chenoa Fund programs. Specific programs covered include Rate Advantage (FHA), DPA Edge: Repayable Second (FHA), DPA Edge: Soft Second (FHA), Conventional Standard 97% LTV Loans, and HomeReady® (Conventional). The training also reviews FHA homebuyer education requirements, verification of housing expense documentation, and alternative qualification options for borrowers with credit scores between 640
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The Steadfast and Reliable Bull: Taurus Zodiac Signmy Pandit
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Navigating the world of forex trading can be challenging, especially for beginners. To help you make an informed decision, we have comprehensively compared the best forex brokers in India for 2024. This article, reviewed by Top Forex Brokers Review, will cover featured award winners, the best forex brokers, featured offers, the best copy trading platforms, the best forex brokers for beginners, the best MetaTrader brokers, and recently updated reviews. We will focus on FP Markets, Black Bull, EightCap, IC Markets, and Octa.
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1. Caring People. Shaping Futures.™
Legislative Update
Changes to COBRA under the
American Recovery and
Reinvestment Act
www.bcgcompany.com
2. Welcome Caring People. Shaping Futures.™
• 2009 Legislative Outlook
• Quarterly Legislative Webinars
– Email newsletters@bcgcompany.com with your contact info to
join our communication list.
• CPE Requests email jennifer.hertzig@bcgcompany.com
• Introduction of the Presenters
www.bcgcompany.com
3. Caring People. Shaping Futures.™
COBRA provisions under the
American Recovery &
Reinvestment Act
Enacted February 17, 2009
Effective March 1, 2009
www.bcgcompany.com
4. Topics Caring People. Shaping Futures.™
• What Health Coverages are Affected?
• The COBRA Subsidy - Who is eligible? Length of
coverage?
• The Second Chance COBRA Election Period
• Action Steps
www.bcgcompany.com
5. Overview Caring People. Shaping Futures.™
• The objective of the COBRA provisions of The Act is to
provide a 65% government subsidy to qualified
individuals for COBRA coverage for a limited period of
time.
• The provisions impose a number of complex
administrative requirements on employers,
administrators and insurers.
www.bcgcompany.com
6. Who is Eligible for the Subsidy? Caring People. Shaping Futures.™
• Any employee or dependent who loses coverage
under a group health plan (a “Qualified Beneficiary”)
is eligible for a COBRA subsidy if they are entitled to
COBRA as a result of the employee’s involuntary
termination of employment during the period
beginning September 1, 2008 and ending December
31, 2009.
www.bcgcompany.com
7. What does “involuntary” mean? Caring People. Shaping Futures.™
• Laid off, downsized, fired: YES
• Quit, retired, leave of absence: NO
• The determining factor is: who initiated the
termination – the employer or the employee?
• Further guidance is likely to be issued by the Treasury
www.bcgcompany.com
8. What Health Coverage Is Affected? Caring People. Shaping Futures.™
• All coverages ordinarily subject to federal COBRA law
and any state “mini-COBRA” laws (i.e., state
continuation laws applicable to employers with fewer
than 20 employees).
• Fully insured and self-insured plans
Note – the subsidy is not available for Health FSA
coverage
www.bcgcompany.com
9. The 65% Subsidy – Effective Date Caring People. Shaping Futures.™
• The subsidy begins with the Qualified Beneficiary's
premium payment for the first period of coverage
following enactment (March 1 or later).
• Neither the coverage nor the subsidy is retroactive to
the date of termination.
• The subsidy is available for up to nine months of
coverage.
www.bcgcompany.com
10. Losing eligibility for the subsidy Caring People. Shaping Futures.™
1. Becoming eligible for coverage under another group
health plan or Medicare.
For this purpose, “group health plan” does not include a
plan that provides only limited benefits, such as dental
care, vision care, EAP, FSA, etc.
Coverage under a spouse’s plan will also disqualify the
subsidy.
The QB is responsible for notifying the plan when other
coverage becomes available, will be liable for 110%
penalty.
www.bcgcompany.com
11. Losing eligibility for the subsidy Caring People. Shaping Futures.™
2. The subsidy starts to become taxable income when
the QB’s AGI exceeds $125k (single) or $250k (joint
return)
Fully taxable if earn more than 145k/290k
The recapture will occur when they file their tax
return (so the employer is not responsible for
monitoring this)
To avoid this recapture, individuals can
permanently waive their right to the subsidy
www.bcgcompany.com
12. Losing eligibility for the subsidy Caring People. Shaping Futures.™
3. When COBRA ends in accordance with standard COBRA
rules
The coverage period expires (generally after 18
months)
The QB fails to pay premiums
www.bcgcompany.com
13. Who Pays What? Caring People. Shaping Futures.™
• The COBRA participant pays 35% of the required
COBRA premium. (See next slide.)
• The employer will still pay the full cost of the
coverage to the insurance carrier as usual.
• The employer is reimbursed the 65% subsidy by the
government in the form of a reduction in their
Federal payroll taxes. (Jessica will cover in further
detail)
www.bcgcompany.com
14. What if … Caring People. Shaping Futures.™
… the employer pays part of the premium?
CAUTION:
The Act contains specific language that states if the QB’s
required premium is something less than the actual cost
of the plan, then the QB’s 35% is based on that
“required premium”.
Therefore the employer’s 65% subsidy rebate is
similarly limited to the lower required premium.
www.bcgcompany.com
15. What if … Caring People. Shaping Futures.™
… the employer pays part of the premium?
Say the employer agrees to pay 50% of the $1000
premium for 6 months in a severance agreement for a
terminating employee.
• Since the employee is only required to pay $500 for his
coverage, under the Act he would only have to pay
$175 (35% of $500).
• The employer would only be entitled to a credit of
$325(65% of $500) for this employee’s coverage, vs.
the full $650 if the employee had been required to pay
the entire premium.
www.bcgcompany.com
16. Offering COBRA with the Subsidy Caring People. Shaping Futures.™
There are two types of Qualified Beneficiaries who
would be offered COBRA with the 65% subsidy:
1. “First Chance QBs” are those who lose coverage by
termination after 2/17/09.
Election notice must be provided in accordance
with regular COBRA notice requirements (within 45
day of event)
www.bcgcompany.com
17. Offering COBRA with the Subsidy Caring People. Shaping Futures.™
2. “Second Chance QBs” who experienced the triggering
event between 9/1/08 and 2/16/09
Must be offered to eligible QBs who originally
declined COBRA coverage and to eligible QBs who
elected and subsequently terminated COBRA
coverage.
The Notice must be sent within 60 days of
enactment (by 4/18/09).
www.bcgcompany.com
18. Second Chance Enrollees Caring People. Shaping Futures.™
• Coverage will commence with the first coverage period
beginning after enactment (usually March 1).
• Coverage will end on the date coverage would
otherwise have ended if the QB had timely elected
COBRA coverage following the QB’s termination of
employment (usually 18 months after coverage was
lost).
• Example: Termination & loss of coverage was October
1, 2008 Second chance COBRA election & coverage
effective March 1, 2009. COBRA coverage ends March
31, 2010 – 18 months after loss of coverage.
www.bcgcompany.com
19. Second Chance Enrollees Caring People. Shaping Futures.™
… thus, second-chance QBs do not have to elect and
pay premiums retroactive to the loss of coverage. They
can and will have a gap in coverage.
Special HIPAA rule: In this case, the period of time
beginning with the qualifying event and ending on
3/1/09 will not be counted as a break in coverage for
purposes of the 63-day pre-existing condition rule.
www.bcgcompany.com
20. Employer’s Action Plan Caring People. Shaping Futures.™
Identify all AEIs currently on COBRA
These are individuals who are QBs based on
involuntary termination of covered employee's
employment on or after September 1, 2008, who
were eligible for COBRA coverage on or after
September 1, 2008, who have elected COBRA
coverage and whose COBRA election is currently in
effect.
www.bcgcompany.com
21. Employer’s Action Plan Caring People. Shaping Futures.™
Identify all other QBs
• Who are or were eligible for COBRA by virtue of any
other Qualifying event between 9/1/08, and 2/16/09,
who have not elected COBRA as of 2/17/09 or who
elected but lost coverage. This includes spouses and
children who were covered at the time of the
qualifying event but are not covered now.
– they must receive a notice of the availability of the
premium subsidy (EVEN THOUGH THEY ARE NOT
ELIGIBLE).
www.bcgcompany.com
22. Action Plan Caring People. Shaping Futures.™
• Determine if you wish to wait on model notices or
draft notices independently.
• Revise election notices if you choose not to wait on
model notices.
www.bcgcompany.com
23. Action Plan Caring People. Shaping Futures.™
• Draft a Subsidy waiver form for highly compensated
employees and an “attestation of eligibility” form for
all individuals who will be entitled to the premium
assistance.
• Revise HIPAA certificates of creditable coverage for
those who take advantage of the special election
period to reflect the fact that any gap between the
date of the qualifying event and the date coverage
begins is not considered a “gap” in coverage for
purposes of HIPAA’s pre-existing condition rules.
www.bcgcompany.com
24. Action Plan Caring People. Shaping Futures.™
• Develop a procedure for QBs who pay more than 35%
during the first two months – will you refund the
excess or credit it against future premiums?
• Calculate the new premium structure to determine
the employee’s 35% portion, and the amount of
subsidy available through payroll offset. Additional
guidance will be issued in the future regarding this
process.
www.bcgcompany.com
25. Action Plan Caring People. Shaping Futures.™
• Review your plan documents, SPDs and related
communication materials (e.g., online summaries) to
determine what (if any) changes are necessary due to
the Act.
• Find out from your payroll administrator how they can
help you track and maintain the payroll information
necessary to fulfill your notice obligations (amount of
payroll taxes offset by the Subsidy, etc.).
www.bcgcompany.com
26. Action Plan Caring People. Shaping Futures.™
• Implement a procedure to send out notices when the
premium assistance is about to be exhausted.
Employers should notify QBs in advance of their
COBRA premium increase after the subsidy runs out.
For example, such notice would be provided when the
maximum nine month premium assistance period
ends, or if the QB becomes eligible for other coverage
under a group health plan or Medicare.
www.bcgcompany.com
28. Employer Reimbursement Caring People. Shaping Futures.™
• The employer must pay the premium in order to be
eligible for the credit.
• The employer must receive the employee’s 35%
portion of the premium.
• Employers can offset payroll tax deposits or claim
the amount on their quarterly filing of Form 941.
www.bcgcompany.com
29. Employer Reimbursement Caring People. Shaping Futures.™
Changes to Form 941
• 12a COBRA premium assistance payments
• 12b Number of individuals provided COBRA
premium assistance reported on line 12a
Visit www.bcgcompany.com for instructions and a copy
of Form 941
www.bcgcompany.com
30. Employer Reimbursement Caring People. Shaping Futures.™
What happens if the payment results in an
overpayment of your payroll taxes?
• Credit applied to next quarter
• Overpayment can be refunded
www.bcgcompany.com
31. Employer Reimbursement Caring People. Shaping Futures.™
Required Supporting Documentation
• Receipt of employees’ 35% payment
• Copy of the invoice from the insurance carrier
• Declaration of employee’s involuntary termination
• Proof of eligibility for COBRA coverage
• A record of the employee’s SSN and how many
individuals this subsidy covers
www.bcgcompany.com
32. Contact information Caring People. Shaping Futures.™
Jim Krosky, SPHR
jim.krosky@bcgcompany.com
(330) 572-8049
Jessica Szydlowski
Jessica.Szydlowski@bcgcompany.com
NEO Administration Company
330-864-0690
COBRA@FlexNEO.com
Q&A’s will be posted at www.bcgcompany.com
www.bcgcompany.com