March
3,
2009
Kapnick
Insurance Group will be responsible
for:
1. Providing (client) with a report
of all employees who were sent COBRA notices since
9/1/08.
(Attached)
What
you (Client) will need to
do:
1.
Review attached report and
assist
Kapnick in determining what employees may be
considered assistance (subsidy)-eligible
individuals. Please review the
employee report and code their
reason for termination.
Codes:
IT = Involuntary
Termination (other than gross
misconduct)
Q =
Quit
R =
Resigned
O = Retired
PL = Permanent
Layoff
LD = Loss of dependant
Status
D =
Death
DV =
Divorce
TL = Temporary
Layoff
RH = Reduction in
hours
2.
Decide
if your organization will allow assistance(subsidy)-eligible
individuals the option to elect a lower-cost plan
within 90 days of becoming eligible for COBRA. The
lower-cost plan must be one that is offered to
active employees.
Upon
Completion of the above, Kapnick will send the
appropriate notices to:
1.
Current
COBRA participants and dependants involuntarily
terminated from employment between 9/1/08 &
12/31/09 that qualify for the
Subsidy.
2.
COBRA
qualifiers and dependants who involuntarily
terminated employment between 9/1/08 &
12/31/09 that qualify for the subsidy but who did
not elect COBRA during their initial qualifying
period.
3.
Former
COBRA participants and dependants with a
qualifying event date between 9/1/08 and 3/1/08
that qualify for the Subsidy but were terminated
from COBRA for non-payment of
premiums.
We ask that the enclosed report be
returned to Kapnick by March 10th,
2009. If you have any questions regarding the
COBRA Subsidy or how to code a termination please
contact Katie Clark at 888-263-4656, x1129. katie.clark@kapnick.com
The Department of Labor has
communicated 3/17/09 as the date their model
notices will be available. Our notices to
Assistance (Subsidy) Eligible Employees will be
sent shortly following this date, or earlier, if a
reliable source can be
found.
To comply with U.S.
Treasury regulations, we advise you that any
discussion of Federal tax issues in this
communication was not intended or written to be
used, and cannot be used, by any person (i) for
the purpose of avoiding penalties that may be
imposed by the Internal Revenue Service, or (ii)
to promote, market or recommend to another party
any matter addressed herein.