Compliance made easy with BCBSGa COBRA Solutions

Compliancemade easy withBCBSGa COBRASolutions

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For over 67 years, Blue Cross Blue Shieldof Georgia (BCBSGa) has been providingGeorgia companies with the choice ofquality affordable health care coveragefor their associates. As the largesthealth care insurer in the state, we offeryou the stability that you can trustand the solutions to make your COBRAcompliance Easy.What is COBRA?The Consolidated Omnibus Budget Act of 1985 (COBRA) requiresthat employers with at least 20 or more employees in the last calendaryear, sponsoring group health plans, offer employees and theirfamilies the opportunity for a temporary extension of health coverage(called “continuation of coverage”). Companies that fall into thiscategory are required to extend COBRA continuation rights, benefitsor coverage to any employee and their dependent covered underthe group health plan that has a qualifying event during the calendaryear of which the company is eligible. It is required that continuationof coverage be at group rates in certain instances where coverageunder the plan would otherwise end. Qualifying events include:• Termination• Reduction of hours• Death of the employee• Divorce or legal separation• Dependent children ceasing to meet eligibility requirements• Dependent coverage is lost because the active employeebecomes entitled to Medicare• Retiree or retiree’s spouse or child loses coverage within oneyear before or after commencement proceedings under Title 11(bankruptcy), United States Code.BCBSGa COBRA SolutionsBCBSGa COBRA Solutions offers you accurate and precise COBRAadministration to reduce unnecessary claims cost and the convenienceof handling your COBRA compliance.COBRA Solutions will administer COBRA for you and provide thefollowing services:• Notify all eligible employees about COBRA continuation• Handle billing, collecting and remitting monthly premiums• Notify COBRA beneficiaries when benefits are scheduled to end• Provide a monthly report to you, the employer, about yourCOBRA membership• Online Access to send COBRA notifications to COBRA SolutionsCOBRA Solutions does not provide:• Annual employee notices or notices to newly hired employeesregarding COBRA services. In the event that you need noticesfor this purpose, copies can be obtained by calling BCBSGaCOBRA Solutions.• Memos or notices to employees regarding benefit changes orpremiums as well as the benefit booklets or contracts associated.Your company should send these documents to the COBRAmembers at the same time that active employees are notified.• Open enrollment information1

COBRA Compliance Requirements• If you maintain an employee health plan which you sponsorfor your employees and you averaged 20 or more employees inthe last calendar year, you are required to offer COBRA to youremployees.• Employees only need to be covered under the health plan for oneday to be eligible for COBRA continuation.• Every employer with 20 or more employees is required to notifyeach employee and their eligible dependent(s) about their COBRArights when they first become covered under the group health plan.• Each time coverage is lost due to a “Qualifying Event” employersare required by federal law to notify the employee within 30 daysof the “qualifying event” even if the employee states that he orshe does not want or need to continue benefits under COBRA.This notice must be sent to the last known address and separatenotifications must be sent to the employees eligible dependentsshould they live at a separate address.• Employers must allow continued coverage for employees andtheir eligible dependents for up to 18 months as a result ofunemployment or reduction in hours. Additionally, an employermay elect to continue coverage for up to 36 months for otherQualifying Events such as:- death of the employee- divorce or legal separation- dependents that cease to be a “dependent” under the terms ofthe group health plan- an employee losing coverage because of Medicare eligibility• Qualified dependents (an employee’s spouse or dependentchild who is covered on the day before the Qualifying Event) areentitled to elect to continue their coverage, within 60 days ofreceipt of the COBRA notification.• The same health benefits offered to active employees must beavailable to COBRA qualified dependents. Dependents may alsochoose from the “core” coverage or other health benefit optionsoffered to active employees.• Employees who elect to continue benefits after a qualifying eventmay be allowed to add new dependents under their extendedcoverage and also change benefits annually if the option isavailable to active employees. This continued coverage must beoffered to eligible employees even if the group falls below 20full or part-time employees.• Initial premium payment for continuation must be receivedwithin 45 days after the date of election by COBRA participants.A grace period of no less than 30 days would be required forall subsequent premiums.• COBRA qualified employees are billed the group’s active healthplan rates plus an additional 2% administrative expense allowedby the COBRA regulation.• If the Social Security Administration determines that the qualifiedbeneficiary is considered disabled under Title II or XVI of the SocialSecurity Act within 60 days of the qualifying event, the continuationperiod must be extended for 29 months from the qualifying eventrather than 18 months. Once the beneficiary is eligible for Medicare,COBRA coverage will cease.• COBRA coverage must be continued even if an exclusion orlimitation with respect to any pre-existing condition affects acontinuant’s current coverage.• Following the expiration of COBRA coverage, the qualifiedcontinuee must be offered continuation coverage under anyconversion plan that is available to the groups employees.• COBRA compliance is serious, therefore, it is advised that legalconsultation supersede any COBRA compliance overview providedin this brochure. Judicial decisions are subject to change at anytime. If you are ever in doubt, please contact an attorney.2

How to Enroll Your GroupTo utilize BCBSGa COBRA Solutions, simply complete the top portionof the COBRA Administration group application. A copy isincluded in this brochure for your use. List your name as it appearson your BCBSGa group application. The contact person should bethe name of the employee or group administrator who is appointedto discuss benefit or COBRA questions from BCBSGa with youremployees. Your BCBSGa marketing representative will completethe remainder of the form with you. Additional information willbe required if your company currently has COBRA participants priorto joining/enrolling with BCBSGa COBRA Solutions. A COBRASolutions Member Notification Form must also be completedfor any/all future eligible participants, submitted either hard copyor via the Internet. A sample copy of this form along with instructionson how to complete it are included in this brochure for youruse. The COBRA effective date is the date this service should gointo effect with BCBSGa. Additionally , you also have the option ofenrolling your associates online via COBRA Solutions Web Access(CSWA) see page 9 for more information.Contact your marketing representative if you have any questionsregarding the COBRA enrollment process.Please note: A service agreement (a copy is included in this brochure)must also be completed at the time of your enrollment. This formprovides an overview of the services performed by COBRA Solutions andoutlines the obligation of your group in the provision of informationto us for the purpose of COBRA administration for you.How to Handle a Qualifying EventAn employee or any dependent needs to be covered by yourgroup health plan for only one day to become eligible for COBRAcontinuation of coverage.Any of the following events that would cause the employee to losehealth care coverage is considered a qualifying event:• Termination of the employee’s employment for any reasonother than “gross misconduct.”• Reduction of the employee’s work hours that would result in theloss of health coverage.• Death of the employee.• Divorce or legal separation.• Dependent child ceases to meet the eligibility requirementsto continue health coverage under the regular health plan.• Dependent coverage is lost because the active employee orCOBRA continuee becomes eligible for Medicare.The COBRA Solutions Member Notification Form must be completedwhenever one of the qualifying events occurs, or you may use CSWA.This form can be sent to the COBRA Solutions office at any time.However, you should not wait longer than 30 days after a qualifyingevent to notify BCBSGa COBRA Solutions.COBRA Solutions will notify the qualified beneficiaries within 14days following the receipt of this form from you. If you use COBRASolutions Web Access, the notifications are mailed the followingbusiness day. It is important that this form be completed fully.COBRA Notice to EmployeesAs an employer, you are required to notify new and all activeemployees and their dependents, covered on the health plan, oftheir COBRA rights. The COBRA notices should be given to eachemployee when he or she is hired and should be addressed tothe employee, their spouse and eligible dependents.If you have not provided this notice, please be sure to send it tothe employee’s current home address. Please note: If you havequestions regarding the “COBRA Notice to Employees”, pleasecontact your attorney for legal advice. If you need a copy of thisnotice, please contact BCBSGa COBRA Solutions at 1-800-292-5615or via email at cobrasolutions@bcbsga.com.3

Employer Instructions for Completing theCOBRA Solutions Qualifying Event Notification FormCOBRA SOLUTIONS MEMBER NOTIFICATION FORMDATE:SEQUENTIAL FORM #1 2 3YOUR GROUP NAME:4YOUR GROUP NUMBER:PLEASE COMPLETE ALL INFORMATION REQUESTEDEMPLOYEE NAME5DOB HCID #/ SSN #TYPECOV-ERAGE6 7 8ADDRESSEVENTCODEQUALIFYINGEVENT DATE(A)BILLINGSTART DATE9 10 11 12EVENT CODES:Please Explain01 - Termination02 – Retirement03 - Medicare04 - Death05 - No Longer an Eligible Dependent06 - Reduce Hours07 – Leave of Absence08 - Divorce/Separation09 – Other(A) Please provide the date to which premiums have been paid.COBRA Solutions will bill from this date.THIS COBRA NOTIFICATION FORM IS TO BE USED TO NOTIFY COBRA ADMINISTRATIONOF ELIGIBLE MEMBERS. PLEASE COMPLETE AND MAIL OR FAX TO:COBRA SOLUTIONSBlue Cross Blue Shield of GeorgiaP.O. BOX 404145ATLANTA, GEORGIA 30384-4145EMAIL: COBRASOLUTIONS@BCBSGA.COMPHONE: 800-292-5615FAX: 404 842-8040NAME OF PERSON COMPLETING FORMPHONE # AND EXTENSIONPLEASE COMPLETE ALL SECTIONS. PLEASE CALL COBRA SOLUTIONS IF YOU HAVE ANY QUESTIONSG-AAD-001976 10/031. The date (month/day/year) that you are sending this form. This formmust be sent to COBRA Solutions within 30 days of the qualifying event.2. Your full group name as it appears on your regular membership billing.3. Your group number as it appears on your billing. Please submit aseparate form for each group that you report COBRA qualifying events.4. Assign a sequential number that will help you identify the forms that yousend to our office should reference be needed to a particular form.5. Give the employee’s full name. Should a qualifying event occur for adependent, please give us the employee information first, followed by thedependent information on the next line.6. Please give the date of birth for the employee or dependent.7. Give us the contract or member number of the employee followed by thesocial security number for any dependents having qualifying events.8. Indicate the type of coverage the qualified beneficiary has with yourgroup at the time of the event. Please select from:S – Single CoverageSP – Two Person CoverageF – Family CoverageE&C – Employee and Child CoverageE&C+ – Employee and Children CoveredE&S – Employee and Spouse Coverage9. Give the current address of the employee or dependent10. The code should be selected from those shown on the COBRA SolutionsQualifying Event Notification Form.11. Give the date of the qualifying event.12. If the member is disabled as determined by the Social SecurityAdministration.Please be sure to mail or fax this form to the address and fax number shownat the bottom.4

PremiumsAs a new group to COBRA Solutions, we will begin billing yourCOBRA participants the appropriate premium following your group’senrollment and the members being placed in the COBRA Solutionssystem. COBRA Solutions will begin sending a set of premium paymentcoupons to the members who enroll. If you have been billingpremiums for COBRA participants, please discontinue, as COBRASolutions will do this for you.All members utilizing COBRA continuation coverage at the timeyou enroll on the service (existing COBRA participants) will receivepremium payment coupons to pay future months’ premiums. Shouldyou receive premium payments from these members, please returnthe payment to them and inform them that COBRA Solutions willbill them directly. As new members enroll in COBRA continuationcoverage, they will receive premium payment coupons. Thesecoupons will reflect your applicable group premium plus the administrativepercentage allowed by COBRA regulation, which is usually2%.The members will be required to pay premiums on the first ofeach month with premiums considered past due after the 30th ofeach month. Coverage is automatically cancelled if premiums are notpaid by the 30th of the month. This is in accordance with the COBRAregulation and strictly adhered to by BCBSGa COBRA Solutions.Exceptions occur when premiums are received in our office after the30th but postmarked on or prior to that date.Monthly premium payments must be paid in full. BCBSGa COBRASolutions does not allow premiums to be broken into smaller increments.However, should a qualified beneficiary desire, they maymake payment for multiple months at one time. Any amounts paidin advance will be subject to rate increases that may occur in yourgroups rate. Should a premium increase occur, the member will berequired to pay the additional premium. Likewise, should a ratedecrease occur, a credit will be given to the member.The first month’s premium may be prorated if cancellation of coverageoccurs other than the first of the month. If you allow coverageto continue through the end of the month in which cancellationoccurs for your active employees, COBRA Solutions will reflect thesame. The first month’s premium will be adjusted accordingly.For Fully Insured GroupsIf you are a fully insured group with BCBSGa, we will take care ofyour membership billing for you. As premiums are received by us foryour COBRA participants, we will update our membership files foryou. No bill will be sent to you for these members. The monthlyreport furnished on the 15th of the month will show which membersare paying for coverage.CoverageCOBRA continuation coverage participants are entitled to the samecoverage offered to active employees. Any previously satisfieddeductibles, stop loss amount or coinsurance will be credited tothe members record. The COBRA participant usually has the samecontact or member number that was assigned under the groupprogram. The group number will change to reflect that the memberis now covered through COBRA. This will have no affect on benefitor benefit levels.The member is entitled to continue the same health benefits thatwere available through active employment. A member may elect tocontinue health coverage only. This option will be available if themember desires. COBRA Solutions will help the member with thiselection. If there are any questions about this procedure, pleasecontact BCBSGa COBRA Solutions.Should a member decline coverage during their 60-day electionperiod, and later decide that they would like COBRA continuationcoverage within the 60-day period, coverage will only be extendedfrom the date the member affirms their decision to continuecoverage. This means that a lapse in coverage may occur. In thissituation, a member may have pre-existing waiting periods apply orother contract obligations that occur when a lapse in coverageoccurs. Please see your contract for information concerning lapsesin coverage.Prior to the cancellation of COBRA coverage, a member and theirdependents will be notified if they can continue coverage on aBCBSGa conversion contract. If no conversion contract is availablethrough your group, benefits will end at that time.COBRA benefits are considered group benefits. COBRA benefits mustbe exhausted before members are allowed to enroll in a conversioncontract with BCBSGa.At any time, a member may elect to enroll in an individual BCBSGahealth care coverage product. Should a member want to examineour individual products, they should contact the BCBSGa officenearest them for more information. These health care coverageproducts may be chosen instead of COBRA continuation coverage.Medical Underwriting and pre-existing condition waiting periodswill apply.COBRA continuation coverage is not allowed when other groupcoverage is elected following the COBRA continuation coverageelection. This also includes Medicare coverage following the COBRAeffective date. Please contact COBRA Solutions at 1 (800) 292-5615for more information.For Self Funded GroupsIf you are a self-funded group or have coverage with another carrier,BCBSGa will refund premiums received for your members to you ona monthly basis. These refunds are sent out around the 15th of thefollowing month when reports are generated.If you have a renewal premium increase or decrease, please notifyCOBRA Solutions of the new amount. Following this notice, COBRASolutions will bill your members accordingly.6

COBRA SolutionsWeb AccessBCBSGa is making it easier for you to do business with us. Inaddition to the helpful resources already available on our Web site,www.bcbsga.com, we are excited to offer COBRA SolutionsWeb Access (CSWA). CSWA allows you to perform changes to youremployees’ records 24-hours-a-day, 7-days-a- week.With COBRA Solutions Web Accessyou can:1. Enter New COBRA Notifications2. Make Changes to COBRA Eligibility3. Save Time and Money by using the Internet to transmit COBRANotificationsWith CSWA you can quickly make additions and changes with ourpaper-free, electronic enrollment service that uses the speed andconvenience of the Internet. It’s easy, efficient and saves you time incompleting your daily tasks. All you need is Internet Explorer version5.0 or later to get started.With COBRA Solutions Web Access it’seven easier to get what you want• Process COBRA Notifications faster than ever with the click ofa mouse• Quickly make additions, changes and cancellations• Embedded hotlinks and convenient drop-down menus reducetyping• ‘Steps’ help to track information input• Error messages ensure accuracy of informationCSWA offers you more control: control over employee informationand control over accuracy of information. Error messages signal thatmissing or incomplete information was keyed in, while electronicprompts guide you from one step to the next, from screen to screen.A copy of the CSWA agreement form is included in this brochure.To find out how your company can begin taking advantage of CSWA,please contact your Account Representative or COBRA Solutions atcobrasolutions@bcbsga.com.CSWA Agreement next page7

COBRA Solutions Web Access (CSWA)Get the Power of Blue SMworking for you.Access Code Policy and Usage AgreementAccess Code Policy:In order to ensure data security, those individuals receiving Access Codes and accessing the computer resources ofBlue Cross Blue Shield of Georgia (BCBSGa), including those of its various affiliates, will adhere to the following methodsof operation:1. Access Codes and passwords will not be revealed by the owner to other individuals.2. No one will use any Access Code and password other than the one issued to him/her.3. CSWA users will not disclose, use, or appropriate confidential or proprietary information beyond which is reasonablynecessary to perform assigned jobs.4. Confidential or proprietary information includes, but is not limited to, the following: medical information, personalinformation regarding members or providers, computer systems or programs, processing techniques, trade secretsand corporate strategies.Violation of this policy by non-BCBSGa personnel will result in immediate termination of the person’s Access Code andreporting of the violation to appropriate BCBSGa management. BCBSGa reserves the right to pursue legal prosecutionunder applicable local, state and federal statutes. Such remedy shall not be exclusive, but shall be cumulative with allother remedies at law or in equity.Usage Agreement:I will accept an Access Code and password that allows me to utilize BCBSGa’s CSWA System.I have read and agree to the BCBSGa Access Code Policy and Usage Agreement as stated above.Name (please print)Signature of UserDate of SignatureCompany NameGroup NumberCompany AddressCity, State, ZIPUsername Email AddressUsername Phone NumberInternal Use OnlyEmployer Group : _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Employer Group #: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Date Agreement Signed: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Access Code Assigned: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Password Assigned: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _Effective Date: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

COBRA Solutions ApplicationGroup Name:Street Address:Mailing Address:City: State: Zip Code:Contact Person, Title:Email Address:Telephone Number:Fax Number:Alternate if possible:COBRA Effective Date:Do not add the 2 percent administrative fee to the rate.Please list all of your health insurance group numbers with the appropriate suffix or subgroups. If there is a different group numberwith each group number, please specify along with the type coverage offered i.e., health, dental, vision, etc. Please give the appropriaterates that are to be billed to COBRA eligible members. (Use additional sheets if more space is needed for the group numbers.)GROUP NUMBER GROUP NAME TYPE OF COVERAGE RATESEmp.Emp. +1Emp. + SPEmp. + Ch(ren)FamilyEmp.Emp. +1Emp. + SPEmp. + Ch(ren)FamilyEmp.Emp. +1Emp. + SPEmp. + Ch(ren)Family

What is your Blue Cross Blue Shield health insurance renewal date?Do you wish to use this same date as the COBRA renewal date? ■ Yes ■ NoIf No,please specify the reason for your requestI am aware that the services provided by COBRA Solutions will commence when I notify COBRA Solutions of a “qualifying event.”I take responsibility to notify all employees of benefit changes,provide benefit descriptions, and rate changes and will also beresponsible for notifying new employees of COBRA.I will notify COBRA as employees or their dependents become eligible under theCOBRA regulations by completing the COBRA Solutions Member Notification form.I am aware that COBRA will bill eligible members based on the information that I furnish.The premium billed to the member(s) willinclude a 2 percent or applicable administrative allowance which will be used by COBRA for this program.If my group health benefitsare fully insured, Blue Cross Blue Shield of Georgia will retain the premium and update the appropriate subscriber/member files.If other than a fully insured, Blue Cross Blue Shield of Georgia will refund premium collected.SignatureDateTitleGroup Name (as used by Blue Cross Blue Shield of Georgia)Blue Cross Blue Shield Representative Name

Blue Cross Blue Shield of Georgia3350 Peachtree Road, NEAtlanta, GA 30326(706) 257-1300www.bcbsga.comUnderwritten by Blue Cross Blue Shield of Georgia,an Independent Licensee of the Blue Cross Blue ShieldAssociation11078 03/05SSMEB-0200-00