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| Could you defend your method of COBRA administration to an IRS
agent or judge? Take this simple test. |
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Do you: |
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Use written
notifications, which have been reviewed by a competent ERISA attorney, to
communicate with beneficiaries about COBRA rights? Do you update these
notifications whenever COBRA law changes? |
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Send each
employee and dependent spouse an initial COBRA notification to his or her home
address when first enrolled in your group health plan? |
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Send a
qualifying event notification to the home address of each qualified beneficiary
whenever a COBRA qualifying event occurs? |
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Know which
events trigger the right to COBRA continuation coverage and which individuals
may be entitled to that coverage? |
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Know how to
administer all of the new COBRA Medicare and disability extension
rules? |
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Know when
administration fees must be reduced from the maximum of 150% to
102%? |
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Grant
mandated extensions of COBRA coverage to the appropriate beneficiaries within
the legal time limits? |
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Know under
which circumstances termination of COBRA coverage is lawfully
permitted? |
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Notify
qualified beneficiaries of conversion options during the required
timeframe? |
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Keep
detailed records of all COBRA-related events? Do you retain copies of all
notices sent, including information about the methods of delivery used? Do you
keep accurate premium collection records? |
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Stay on top
of changes in the law as they occur? |
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Have
methods in place to maintain institutional memory when the individual
responsible for administering COBRA leaves your employ? |
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If you answered NO to any of these questions,
you are exposed to the risk of IRS and ERISA penalties, as well as costly civil
lawsuits. |
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