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436 PART 4 COMPENSATION<br />

FIGURE 13-4 COBRA<br />

Record-Keeping Compliance<br />

Checklist<br />

Source: Reprinted from<br />

www.HR.BLR.com with permission<br />

of the publisher Business and Legal<br />

Resources, Inc., 141 Mill Rock Road<br />

East, Old Saybrook, CT © 2004. BLR ®<br />

(Business and Legal Resources, Inc.).<br />

Detailed record keeping is crucial for COBRA compliance. The following checklist is designed<br />

to ensure that the proper records are maintained for problem-free COBRA compliance.<br />

Do you maintain records so that it is easily determined<br />

who is covered by your group health care plan?<br />

Do you record terminations of covered employees as<br />

soon as terminations occur?<br />

Do you track reduction of hours of employees covered<br />

by group health care plans?<br />

Do you track deaths of employees covered by group<br />

health care plans?<br />

Do you track leaves of absence of employees covered<br />

by group health care plans?<br />

Do you track Medicare eligibility of employees covered<br />

by group health care plans?<br />

Do you track the disability status of employees covered<br />

by group health care plans?<br />

Yes No<br />

Do you track retirees covered by group health care plans?<br />

Do you maintain current addresses of employees?<br />

Do you maintain current addresses of individuals<br />

receiving COBRA benefits?<br />

Do you require employees to provide a written<br />

acknowledgment that they have received notice of their<br />

COBRA rights?<br />

Do you have a system to determine who has paid<br />

COBRA premiums on time?<br />

Do you have a system to determine who has obtained<br />

other group health coverage so that they are no longer<br />

eligible for COBRA under your plan?<br />

Do you maintain a telephone log of calls received about<br />

COBRA?<br />

Do you maintain a record of changes in your plan?<br />

Do you maintain a record of how premiums are calculated?<br />

Do you maintain a log of those employees who are<br />

denied COBRA coverage?<br />

Do you maintain a log of why employees are denied<br />

COBRA coverage?<br />

For many employers, deductibles and co-pays are the low-hanging fruit in health<br />

care cost control. For example, 22% of employers imposed deductibles of at least<br />

$1,000 in 2011 for in-network services, up from 8% in 2008. 57 Even more 44%<br />

imposed such deductibles for out-of-network services. 58 Consumer-driven health<br />

plans (CDHPs) are increasingly popular. These are high-deductible plans that give<br />

employees access to, for instance, a health savings account. (The Medicare Modernization<br />

Act of 2003 allows employers to establish tax-free health savings accounts<br />

(HSA).) 59 After the employer, employee, or both deposit pretax (and thus tax<br />

sheltered) pay in the employees HSAs, employees or their families can use their HSA<br />

funds to pay for low dollar (not catastrophic) medical expenses. 60 The assumption<br />

is that this will motivate employees to utilize less expensive health care options, and<br />

thus avoid big deductibles. 61 Employers generally offer CDHPs as an option to<br />

traditional plans, such as PPOs. 62 We ll address other important cost-control trends.<br />

COMMUNICATION AND EMPOWERMENT Most importantly, make sure<br />

employees know the costs of their medical benefits. 63 As one expert said, the biggest<br />

criticism of managed care . . . is that the health care consumer has little financial stake

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