I am by no way an expert on this, however, during a seminar with my FSA/HRA/Cobra provider I have gathered the following.
That the DOL has been given until 3/19/09 to provide updated model notices that include all of the language required by ARRA. (American Recovery & Reinvestment Act of 2009)
There are the Potential AEI’s (Assistance Eligible Individuals) and the Existing AEI’s. An existing AEI is an employee that is currently on Cobra. A Potential AEI is an employee that lost insurance coverage between 09-01-08 and 12-31-09 and either did not elect cobra or opted out of Cobra and now must be given a second chance.
The act contains several new notice requirements for employers. Until the DOL gets sample notices out the employers must change their existing notices to add the following information.
A) A notification shown in a clear manner that the recipient has the right to a subsidized premium and any conditions to the right.
B) A description of the extended election period for those employees who previously declined Cobra coverage
C) A notice stating the qualified recipient’s option to enroll in different coverage than what they had previously enrolled in under Cobra of such election is prmitted under the employer’s insurance plan. This means if the Dental and Medial and FSA are separate than they could take only one or the other if they wished. If you have PPO, HMO and different coverages they may now elect to select a different less expensive coverage option.
For the eligible employees terminated between September 1, 2008 and February 17, 2009 the modified notice must be provided on or before April 18, 2009.
The IRS website has information at the IRS.gov website on how to prepare the 941 forms .
http://www.irs.gov/newsroom/article/0,,id=204709,00.html
Maybe someone else can add more, I am still learning about the new changes myself.
If I can help further please let me know.
Shirley
Shirley McAllister
Director of Human Resources
Aim International, Inc.
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