COBRA has been difficult to manage since 1987, until now.
Notifying TPA’s of qualifying events has been a manual process for HR managers and TPA’s. Gathering the employee and dependent data as well as plan and termination information is prone to errors and is time-consuming.
We’ve Modernized the Data Exchange
Employee Navigator understands the complexity and importance of the COBRA law. We have succumbed to developing tools to support both the management and notification facets of COBRA. Employee Navigator has all of the plan, enrollment and event data for customers who manage benefits, and we’ve put it to good use. When terminations or life events take place, we log the event in our system. Participating TPA’s can then access Employee Navigator and request all of the qualifying events and new hires. You still need to select and coordinate the implementation of the TPA and sign the necessary agreements with your TPA, that part hasn’t changed, but we are working on it.
There are two parts of COBRA in Employee Navigator- Enrollment Management and Notification.
We have developed a COBRA Dashboard which is a visual analysis of data that displays the status of Cobra participants for each Company built in our system. The Dashboard surfaces COBRA candidates who are considered eligible for COBRA, actively enrolled, and employees who have terminated their coverage.
Managing COBRA participants in Employee Navigator is fairly an easy task to do, now the next step is getting enrollment data to Carriers. Employee Navigator has developed a Data API to notify a Third-Party Administrator (TPA) of events which will require an Initial Rights Notice or a Qualifying Event Notice as part of the COBRA requirements.
How Much Does It Cost?
You still have to pay the normal COBRA fees to a TPA... but that’s it. We take care of everything on the back end for you, for free!
TPA’s are now more efficient
As part of the service, we combine COBRA activity for multiple companies in a single file. That means participating TPA’s can log into Employee Navigator and download a single file with life events spanning hundreds of companies and import the events in a single report. We also let TPA manage and approve companies participating the program.
Take a look and see how easy it is use
To view the recorded Webinar on the Employee Navigator COBRA Exchange conducted by George Reese on 02/12/2015, click here. This can also be found in the Webinars section of this site.
What about brokers who are managing COBRA internally for their clients?
We understand that some agencies are provided this service for their clients and are processing in house. In time, we will have the functionality to allow an agency to suppress the exchange services from being displayed at the client level.
We are a broker processing COBRA in-house for our clients. Is there a way that we can get setup as a TPA for our clients?
We are currently gathering data and considering how this feature could be turned on for brokers to have access to the file generation process. We will update the support site as we make changes to the COBRA product. You can subscribe to the COBRA section in our support site and receive an email when we update an article with more information https://employeenavigator.zendesk.com/forums/21173499
Will each vendor be able to provide services in all states and will the TPA only do only COBRA or will the TPA also pick up information for mini-COBRA and State Continuation?
You will need to contact the TPA directly to have them define their scope of capabilities.
Cost & Billing
What are the fees for the COBRA administration?
All fees for COBRA administration are contracted directly through the TPA and Employee Navigator is not a part of that process. You should work with the vendor directly to determine those fees and who will be paying the fees for the service.
How do I setup my plan to auto drop any over age dependents?
Currently, this is available in our medical, dental and vision plans and must be configured when using the COBRA product. Read the following support article for full details on how this works https://employeenavigator.zendesk.com/entries/78286845
How should we manage grandfathered Employees or special situations?
Any special situations should be discussed directly with the TPA
Do you support bundled plans?
Why do I need to unbundle them for the COBRA tool? Let’s look at an example to explain why this needs to be done. Ex: You have a combined medical and dental plan and built a single plan in Employee Navigator. Based on COBRA regulations, you may need to allow an employee to elect COBRA for the dental plan only. If this is the case, we cannot split up a medical plan, you should build separate medical and dental plan and use our plan restriction tool to ties the medical and dental plan together. So in summary, if you expect to have 2 qualifying events sent to the TPA, set up 2 plans.
Enrollments and Qualified Events
What is the best way to process life events?
Life events should not be done via the Enrollment Editor. When using our COBRA product, you must use the Life Event tools to enter these changes in the system. An administrator can use the Update Benefits tab and an employee can use the Change Coverage option in their Benefits tab to make these changes.
Using the Enrollment editor for life event changes will NOT create a COBRA notice.
What employee information is required to process a COBRA record?
Before you terminate an employee or dependent, you must enter the following information: SS#, Date of birth, & Gender. This will ensure the data populates correctly in the COBRA file.
When an employee is terminated in EENav, does the TPA get notified immediately or is there still a manual step?
Once the agreed upon Go-live date has passed the QE or Initial Rights Notice life events that are processed in Employee Navigator will automatically be included in the file for the TPA. The TPA will come into Employee Navigator on their own schedule to pull events.
Does this service only cover COBRA QE or will it also handle Initial Rights Notice?
This product has the functionality to handle COBRA QE and Initial Rights Notice reporting. Which reporting is sent to the TPA depends on the contract with the company.
If they elect COBRA will that feedback into EENav?
No, Employee Navigator does not receive data back from the TPA. You will need to discuss with the TPA how enrollment and termination information should be handled for COBRA.
How can we see what QE’s have been submitted and when they were submitted?
For phase 1 of this product release the visibility into this data is not available. You will want to check in with your TPA to ensure that notices are transmitted. Employee Navigator will be working on an enhancement for this reporting feature so that in the future there will be more visibility into what has been reported to the TPA.
Will EENav maintain a record of the date notices were sent?
No, the TPA is the record holder of this information and it will not be transferred back to Employee Navigator.
How is COBRA for FSA plans handled?
If we are transmitting COBRA coverage for a cafeteria plan, the TPA must determine the eligibility based on a positive account balance for the employee.
COBRA systems generally have an option to send COBRA notice reminders monthly or a coupon book. We’ve set our default to coupon book.
Transitional Audit Report:
We created a Transitional Audit Report for COBRA vendors which will provide a list of ended enrollments for COBRA eligible benefits were either the coverage end date or the coverage ended on the date is between today and 110 days ago. Tweaks to this logic may continue to occur over the short term. This report should be used to audit that the COBRA eligible events were all passed to the COBRA vendor.
The Ongoing tab will be used exclusively for performing since-last processing on date-based (currently only COBRA) exchanges.
There are no time-span selection options when generating data exchange files on the Ongoing tab; every request will perform since-last processing, which sets the from/start date value to the to/end date and time of the last file that was run for the exchange from the Ongoing tab, and sets the to/end date to the current date and time.
The first time a file is generated for an exchange on the Ongoing tab, the from/start date will be 1/1/2017 at 12:00am and the to/end date will be the current date and time.
To avoid a COBRAPoint error, ensure that the plan names in Employee Navigator match the plan names in COBRAPoint. Upon receiving a new connection request and prior to testing, select the plan map to view the plan names that have been populated by the Broker/Company in Employee Navigator. Use the plan mapping feature to make any necessary adjustments to the plan names.
COBRAPoint Division Mapping:
It is Employee Navigator’s understanding that COBRAPoint requires that a “division” field be populated within their system. Additionally, what Employee Navigator sends on the file to populate the COBRAPoint division field must match the COBRAPoint setup. The class structure is the foundation of our system. Many clients will use several classifications for employees and it is important that we get the correct data on the COBRAPoint file so we’ve created a Mapping tool for the TPA to ensure accurate field population.
The COBRAPoint division(s) can be mapped by the TPA for each company. We configured this option at the vendor permission level to ensure data integrity. Company administrators may not be aware that changes to class structure will affect the COBRA file. This vendor level mapping will override the company data. Here’s how it works: If there is no Company Identifier mapped, we will send the Client ID (also known as the Company Identifier), which is set up by the TPA upon acceptance of the newly connected company. However, EN offers additional mapping options that can be utilized by the TPA which include the company’s divisions, departments, business units, classes, or the company identifier. Keep in mind that the only field of the additional mapping options that is required within Employee Navigator for all employees is the class field, therefore, if you are mapping one of the other available fields such as division or department, you'll want to remind your client that all employees must have a value selected for that field to avoid file errors.
COBRAPoint Coverage Level Mapping:
Employee Navigator and COBRAPoint do not use the same Coverage Levels. We mapped our coverage levels to those in COBRAPoint. Please ensure that your COBRAPoint configurations align with the coverage levels set per plan in Employee Navigator.
|Employee + Spouse||EE+SPOUSE|
|Employee + One||EE+1|
|Employee + Child||EE+CHILD|
|Employee + Child(ren)||EE+CHILDREN|
|Employee + Family||EE+FAMILY|
|Employee + Spouse + Child||EE+2|
|Employee + Two||EE+2|
|Employee + Two Children||EE+2|
|Employee + Spouse + Two Children||EE+SPOUSE+2CHILDREN|
|Employee + Three||EE+3|
|Employee + Three Children||EE+3|
|Employee + Spouse + Three Children||EE+SPOUSE+3CHILDREN|
|Employee + Four||EE+4|
COBRAPoint Qualified Event Types:
Employee Navigator and COBRAPoint do not use the same Qualifying Event Types. We mapped our COBRA qualified event types to those in COBRAPoint.
|Divorce or legal separation (36 months) / Divorce or Legal Separation (COBRA)||DIVORCELEGALSEPERATION|
|Death of Employee / DEATH||DEATH|
|Loss of dependent child status (36 months) / Dependent Leaves or Completes College||INELIGIBLEDEPENDENT|
|Covered employee's becoming entitled to Medicare / Medicare||MEDICARE|
|Reduction in Hours (18 months) / Reduction in Hours (COBRA)||reductioninhours-statuschange|