2021 COVID-19 COBRA Extensions Compliance Information

It has been one year since the relaxed COBRA timeframes became effective on March 1, 2020 and as we reach the 1 year anniversary we finally receive guidance from the Department of Labor in the form of a “Joint Notice.” The joint notice is a collective effort from the Department of Labor, the Department of the Treasury, and the Internal Revenue Service.

The joint notice reveals that the Outbreak relief period is expressly limited by statue to a period of one year and each qualified beneficiary will be treated on an individual bases and be allowed the 1 year timeframe extension or until the outbreak has ended.

Obviously this puts a huge burden on employers and COBRA administrators. Trying to track all these new timeframes is very difficult. This is where your software comes in to play. With version 21.3.x (available for download now), your software will do the following things.

• Track 1 year anniversary dates for each QB
• Terminate coverage for participants that have passed their 1 year anniversary (applicable COBRA timeframes still apply).
• Return to normal 45-day and 30-day payment grace period for COBRA participants that have have passed their 1 year anniversary.

With all these new changes, we have a couple of examples that should help you understand the how the election and premium payment grace period extensions will end.

Example 1: Thomas has a COBRA qualifying event on September 30, 2020, but does not elect COBRA. Assuming the national emergency is not ended prior to September 30, 2021, Thomas will receive 60-days after his 1 year timeframe extension (November 20, 2021) to elect COBRA.

Example 2: Debbie has a qualifying on August 31, 2020, but does not elect COBRA. On May 31, 2021 the president ends the National Emergency. Debbie will receive 60-days after that and then another 60-days (normal COBRA timeframe) to make her COBRA election (or until September 28, 2021).

Update your Software

The most common method for obtaining the update is to:

1. Under the File menu, select the “Update Software via Internet” option. (If Microsoft Windows asks if you wish to start as “Administrator,” select “No.”).
2. Click the Next button to access the files.
3. You will be asked if you wish to review the new letters. You can select the desired letter and you will be shown the changes in red text.
4. Click the Next button and you will be provided a button to select the letters you wish to update and the groups that will be updated. If you do not select the letters (not recommended), they will not be updated in your system.
   1. If you are a Third Party Administrator and make changes to the notice (i.e. letterhead), you may only want to update one group.
   2. Upon completion, you can add/remove information as you wish and then save the document.
   3. Once saved, close the document and then go to the  Notifications menu heading.
   4. Select, Copy Letters to Other Groups.
   5. Pick the altered letter(s) and the groups you wish to update.
   6.  Finally, click the Copy Now button.

Upon completion, you will be given a Congratulations message and the COBRA software will restart.

If your firewall blocks you from obtaining the update through the software (as described above), you can directly download it by visiting www.cobrasolutions.com/firewall.

1. Click on the “Updating Version 20 when you have a firewall.
2. Follow the instruction on the web page.
3. Under step #3, you will be asked to provide a password for the update.  The current password can be found in the emailed version of this newsletter (right column).
4. Continue to follow the steps followed by entering the COBRA Administration Manager and replace the current letters with the new ones. (If you are a TPA, you may want to update just one group first, following step 5 above.).

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