Health Flexible Spending Accounts (FSAs) are subject to COBRA.  However, most FSAs are only required to offer COBRA if the account has a positive balance.  In other words, the beneficiary has contributed more that he or she has received in reimbursements.  If the account is overspent, COBRA does not have to be offered. 

In a somewhat expected move, the IRS announced a last-minute extension of the looming deadlines for Forms 1094 and 1095.  The extension is good news for employers and insurers still trying to figure out exactly how to report all of the necessary information for 2015.  

Employees losing employer group health coverage may be surprised to learn that selecting a Marketplace or individual plan with an extremely high deductible will render them ineligible to contribute to their Health Savings Account (HSA).

Thus far, the 2016 Marketplace open enrollment season has signaled nothing but stormy seas ahead.  In order to receive a federal subsidy to help pay for health insurance, qualifying individuals must purchase health insurance through the federal Marketplace or a state-sponsored exchange.  So, what happens when insurers stop offering coverage through the Marketplace?

The very first Affordable Care Act (ACA) reporting deadline is quickly approaching. In fact, individual statements must be sent to employees no later than February 1, 2016.

Do COBRA obligations exist even if coverage does not end? This seems like a silly question. COBRA, after all, provides continuation under an employer’s plan after a loss of coverage. However, as with most things involving health insurance (think Affordable Care Act), the term “loss of coverage” is more complicated than you may think.

Summer has officially ended.  By now, your kids are back in school, your tan is fading and the end of the year will be here before you know it.  It is time to play catch-up on ACA reporting. 

On July 6, 2015, President Obama signed the Trade Preferences Extension Act of 2015.  The Act retroactively reinstated a refundable federal tax credit of up to 72.5% of the cost of qualified health insurance premiums – including COBRA.  The tax credit is generally for individuals in certain industries whose jobs are lost or threatened due to foreign-trade related circumstances and for individuals over age 55 receiving payments from the PBGC relating to a terminated, underfunded pension plan.

There are several tricky scenarios that arise when coordinating COBRA coverage under the Affordable Care Act (ACA).  Case in point: Alex lost his job in August and elected COBRA coverage. However, he subsequently stopped paying his COBRA premiums and his COBRA coverage ended effective 10-31-14. He thought that he could score more affordable coverage through the Marketplace, but soon learned that because he let his COBRA expire, he was not eligible to apply for Marketplace coverage until the next Open Enrollment period, and then, his coverage would not become effective until January 1.

In this crazy post-ACA world, everyone is struggling to learn how the new rules apply to COBRA administration.  Now more than ever, it is important to revisit the basic building blocks of COBRA.