The COBRA Maze

Today, April 18, 2009, is COBRA Subsidy Notice Day -the deadline imposed by the American Recovery and Reinvestment Act to send COBRA notices to those involuntarily terminated after September 1, 2008.

Not exactly the same as Paul Revere’s ride, the event 234 years memorialized by Henry Wadsworth Longfellow’s poem and remembered in Massachusetts with Patriot’s Day.  With apologies to Hank, I offer this little ditty to memorialize the event occurring this year..

Listen my public and you shall cuss
About the COBRA part of the stimulus
Twas the eighteenth of April in twenty O nine
When out was tossed a feeble life line

Those who imagine that a “government run” health care system might mean more bureaucracy should spend some time familiarizing themselves with COBRA.

Certainly since the ARRA law was signed on February 19th and the regulations and additional “guidance” were released on March 30th, there has been ample opportunity.  Our office has been flooded with solicitations for seminars and webinars, and guidance form assorted professional organizations.

It is a sad reflection on the values of our society that an event as disruptive as job loss is compounded by the loss of health insurance.  COBRA was designed to alleviate that somewhat by permitting people to continue on their employer’s plan as long as they paid the full cost.  Very few – only those with expensive on going treatments – take advantage of it. 

Those interested in more information about regular COBRA should visit the Department of Labor website.  If you are interested in COBRA under the ARRA, visit the CMS website.

The Obama Plan attempts to make COBRA more affordable for some people.  That’s what our government does best.  Programs for some people.  Programs for everyone are a lot simpler and a lot fairer.  Those are called Entitlements.  Those are bad according to those on the right.

Programs for some people are called Bureaucracies.  Those are bad too, but not quite as bad as Entitlements. Because the programs are only for “some people”, Bureaucracies have to make complicated rules that describe who the “some people” are and the tortuous route that need to travel to get whatever it is they are seeking.

So our plan had 2-4 weeks to learn about the new COBRA notice requirements, and send notices to approximately 100 people who may have been involuntarily terminated since September 1, 2008.

I start out by signing up for one of the free webinar’s, instead of paying the $150-$200 to those who exploit the economic opportunity offered by ARRA.

Then I need to wade through the four pages of guidance provided by our consulting firm and the six pages offered by our lawyer (for free of course) so that I can decode which notice I send out to whom.

Is it the  16 page new Standard Notice that is sent to qualified beneficiaries with qualifying events occurring between September 1, 2008 and February 16, 2009 who: (1) have not yet received an election notice; (2) received an election notice that did not contain information about the ARRA subsidy; or (3) are currently in their election period.

Is it the 11 page Supplemental Notice that is sent to qualified beneficiaries with qualifying events occurring between September 1, 2008 and February 16, 2009 who have already elected and still have COBRA coverage?

Or is the 15 page Additional Notice to be sent to qualified beneficiaries with qualifying events that occurred between September 1, 2008 and February 16, 2009 who are or who would be “Assistance Eligible Individuals” but are not enrolled in COBRA coverage.  This includes individuals who either failed to elect COBRA when first eligible, or who elected it and later dropped the coverage.

The fifteen pager won out, and I hope we are right.  We had no one currently on COBRA who fell into the category of “involuntarily terminated”.

All of this economic activity occurs with no direct connection to medical care.  It is what is referred to by those in the single payer camp as “administrative waste.”  It is what would be saved when we move to a single health care program for everyone instead of different programs for “some people.”

Meanwhile, I do hope that some of the “some people” will benefit from this life line as feeble as it may be.


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