This post is going to be a little different from our previous posts. I’ve been feeling guilty for the massively long articles we’ve been posting, so I’m going to try to be succinct. FDR had a great thought on this subject which I try to follow: “Be sincere; be brief; be seated.” So in that spirit, here goes:
Our other teammate in Dallas is JoAnne, a Solutions Consultant who just wrapped up a mini research project around how COBRA vendors are preparing for the rollout of the ACA mandated Healthcare Exchanges/Marketplaces.
As she was thinking about this, it seemed that a COBRA administrator would like for the employee/families to choose COBRA through them, as this is the way they get their 2% administration fee which is based on the paid premiums. They might not want to incent them to go elsewhere.
Now, an employer and/or their Benefits Administration vendor SHOULD want to incent COBRA participants to choose the exchange. It would be a win-win: the employer gets the person off the plan and the person may qualify for a subsidy on the exchange. This would be in the best interest of the employer.
The service bureaus that offer comprehensive HR/Payroll/Time/Benefits with some administrative services like COBRA, such as Ceridian and ADP, thought it was a great idea; however, the folks we talked to were not aware of anything on their roadmap to support such a process. Please note, with thousands of people in the vendor organizations who COULD possibly answer the question (or THINK they should), we have to rely on the people who serve as our alliance/channel point of contact for these (and all) vendors. They always want us to include a warning that they can never promise us 100% accurate answers – especially with ancillary services like COBRA that tend not to get as much attention.
The COBRA specific vendors, such as Discovery Benefits, seemed to have put the most thought into this as at least they replied with their intentions to mention the Public Marketplace exchanges on the COBRA notifications. This will be in effect for terminations 1/1/2014 and after. No benefit plan descriptions or premiums will be on the notices.
Please comment below if you have any additional insight or thoughts on this topic.