TravisCobra State-Specific Module Now Available

Travis Software is pleased to announce that deliveries have begun of the newest member of its COBRA/HIPAA software product family, the "State-Specific Continuation Module for Over-20 Employee Groups."

Building on interest in the ever-growing number of state-mandated group health continuation laws among employers and continuation coverage administrators, Travis has spent the past two years researching state laws and "programming them into the system" just as the Federal COBRA law was programmed into TravisCobra beginning in 1986.

This new module is actually the second involved with state continuation Travis has developed. The first module addressed the 46 states which have legislated continuation coverage for employees and dependents covered by insured group health plans based in their state for groups of 2-19 employees. That module, the "State Specific Module for Under-20 Employee Groups" is designed for use by administrators who work with those small employer groups. That module was completed and delivered to its first customers in January, 2003.

TravisCobra has always been designed to help meet the administrative requirements of the Federal COBRA and some aspects of the HIPAA law. Over the years capabilities have been added that allowed users to partially administer state continuation, but the user had to know the state laws themselves in order to know how to "trick" the system so that state requirements could be met. The SS20+ Module has the state laws' administrative requirements "programmed into the system" just as the COBRA law has always been programmed into TravisCobra. As a result, system operators don't need to know the specific provisions of each state continuation law - they only need to know what state's laws the insured plans or HMOs must observe.

How the Module Works:
The module being announced via this email, the "State-Specific Continuation Module for OVER-20 Employee Groups" or as we abbreviate it, "SS20+," helps users coordinate the administration of both Federal and State continuation mandates, notifying continuees of their state-mandated rights and transitioning them from their Federal continuation period into State continuation automatically, adjusting their premium billings, end of coverage periods and plans in which they participate.

SS20+ is designed for use by administrators and employers having to coordinate both COBRA and State continuation for the ten states whose laws extend coverage on insured plans/HMOs governed by laws of their states past the mandated COBRA periods. It is those ten state "mini-modules" that make up the SS20+ offering.

If you offer or administer plan(s) based in California or the other nine states whose laws can extend continuation past the COBRA period, once you license SS20+ TravisCobra will automatically notify continuees who participate in insured group plans based in the state(s) you license of their rights to extend their coverage, print their application to the carrier(s) for the extended state coverage and, if applicable, automatically adjust the premiums due when COBRA ends and state continuation begins and track their state-mandated coverage periods.

The state modules also allow users, at their option, to continue to bill the premiums due during the state continuation period, notify if premiums are late, and terminate for non-payment when appropriate. Since most of the ten states require that continuation only be extended on some plans rather than all health plans as COBRA requires, the state modules will only communicate continuation offers and bill premiums only for the indicated plans.

California's module, as an example, is designed to meet Cal-COBRA, passed in 1998, and A.B. 1401, passed in late-2002 by the California Assembly, which mandates a total of 36 months of continuation including COBRA coverage for those covered by insured health plans/HMOs governed by California's laws (state continuation begins when COBRA coverage is exhausted). The California law also provides that employees over 60 at the time of their qualifying event who have been employed by the employer five years or more may remain in the group plan until 65, but premiums may be much higher during the post-COBRA period. TravisCobra with SS20+ for California will:

1. Disclose the possible state extension in the initial COBRA election notice printed at the beginning of the 18- or 36-month Federal continuation period;
2. Disclose that the continuee, if disabled, may want to subscribe to the state coverage after the 18 months of Federal continuation is concluded, rather than to the 11-month Federal disability extension, since the state has a cap of 110% of premium that can be charged during its period but Federal law allows 150% to be charged.
3. Remind the QB as the Federal period is ending that the state continuation is available, and print the application letter required to be sent to the carrier,
4. Confirm to the QB when COBRA ends that the QB is now beginning their state continuation period,
5. Automatically adjust the premium for medical plans at the beginning of state coverage from the (generally 102%) COBRA premium to what the administrator has specified (100-110% for months 19-36 and up to 213% for qualifying "over 60" continuees). The Status Code for the QB will also automatically change, from "Enrolled-COBRA" to a new code, "Enrolled-State Continuation."
6. Optionally, continue to bill the QB premium during the state continuation period, and report/remit premiums collected.
7. Confirm when state continuation has ended, if TravisCobra has been used to bill premiums during state continuation.

The state-specific modules require some new information about the QBs and Benefit Plans to be stored in TravisCobra's data files. For the first time it is necessary to differentiate between insured and self-funded plans, since ERISA self-funded plans don't have to meet the requirements of the state continuation laws. Benefit Plans in TravisCobra once the State Continuation Module is installed need to indicate if the plan is self-funded, and a new field has been added for that purpose. If the plan is not self-funded, the system will ask the state law that governs the terms of the plan.

Once that information is known, TravisCobra will know which state's rules to invoke when QB's must have continuation extended past the COBRA period. Coverage extension notifications, adjustments to premium billings and correspondence to both continuees and carriers indicated by individual state laws will be customized to each state and automatically generated by the system. TravisCobra system operators will not need to know the particulars of each state's continuation laws.

Here are the ten states currently mandating longer-then-COBRA coverage in certain circumstances, together with a brief explanation of their provisions:

California - explained above

Georgia covered employees over 60 offered coverage until eligible for Medicare

Illinois spouses over 55 may get coverage until eligible for Medicare

Louisiana surviving spouses may continue coverage indefinitely

Minnesota extensive state law, particularly with respect to disabled and spouses

Missouri up to 10 years coverage on medical plans for spouses

New Hamp. coverage until 65 for spouses

Oregon medical coverage until Medicare if spouse if over 50, all plans if over 55

Rhode Island "infinite" coverage for spouses if specified by court

Texas six-month state continuation "tacked on" once COBRA exhausted

If you have employees participating in insured plans in these states, or if you're an administrator and your clients have employees participating in insured plans or HMOs based in these states, you may need to install this new module.

Contact Info:
Travis Software
Garth Williams
Vice President
(281) 496-3737