WebCOBRA Press Room

Single Sign-On Feature Now Available in WebCOBRA

Tues, 24, Feb 2009 10:00:00 CST

Single Sign-On Feature Now Available in WebCOBRA

Travis Software enables users to log in via their own website or intranet.

Houston, Tex. - February 24, 2009 - Travis Software Corp., a market leader of advanced employee benefits software administration, announced today the addition of Single Sign-On to the WebCOBRA.com features list.

With the Single Sign-On feature, users can now log into WebCOBRA from their own website without having to remember an additional password. Users can integrate the sign-in and sign-out functions of WebCOBRA via their own website, intranet, or Windows login.

“Security was the top priority when we were developing the Single Sign On feature,” said Jesse Wolgamott, president and COO of Travis, “In order to allow a user to log into WebCOBRA from their own website, we used the same technology that Amazon.com uses in their web services. We create a random secret key that only the user and their programmers will use, so that they can “Sign In” to the system and WebCOBRA knows to trust them.”

For more information about the Single Sign-On capability offered by WebCOBRA, please visit our website at www.webcobra.com or log onto the Travis Blog at http://blog.travisoft.com.

About Travis Software Corp.
Travis Software Corp., based in Houston, Texas, was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the company's COBRA administration software system, TravisCobra, and its Web-based system for COBRA, WebCOBRA.com.

Trademarks
WebCOBRA.com is a trademark of Travis Software Corp. Microsoft and SQL Server are registered trademarks of Microsoft Corporation in the United States and/or other countries.

For more information about WebCOBRA, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email us at marketing@travisoft.com or visit us at www.webcobra.com.

COBRA Changes due to the American Recovery and Reinvestment Act of 2009

Thur, 19, Feb 2009 10:00:00 CST

COBRA Changes due to the American Recovery and Reinvestment Act of 2009

Houston, TX - February 19, 2009 - Travis Software Corp., a market leader of Advanced Employee Benefits Software Administration, announced today the changes being made to the TravisCobra and WebCOBRA systems in compliance with the American Recovery and Reinvestment Act of 2009, ARRA.

Due to the recently passed ARRA, Travis is working hard to ensure that the TravisCobra and WebCOBRA systems are in full compliance of the new COBRA regulations. Some of the changes you can expect include:

Subsidy calculation of 65%.

Report that will summarize the Premium Subsidies.

New Notification Letter and Re-Enrollment Form with a disclaimer of, while the QB can apply for the subsidized benefits based on their belief that they were involuntarily terminated, they understand that the IRS will reclaim the subsidy from the QB if they accept the subsidy and it later turns out their income was higher than the threshold levels.

Adding a “check-box” to the QB’s record to denote them as “Involuntarily Terminated and Eligible for Subsidy.”

For more information regarding the changes to the TravisCobra and WebCOBRA systems, please visit the Travis Blog at http://blog.travisoft.comhttp://blog.travisoft.com.

About Travis Software Corp.
Travis Software Corp., based in Houston, Texas, was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the company’s COBRA administration software system, TravisCobra, and its Web-based system for COBRA, WebCOBRA.com.

Trademarks
WebCOBRA.com is a trademark of Travis Software Corp. Microsoft and SQL Server are registered trademarks of Microsoft Corporation in the United States and/or other countries.

For more information about the WebCOBRA.com Summer ’08 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at marketing@travisoft.com or visit Travis Software at www.travisoft.com.

WebCOBRA.com Expands its Free Online Video Training for all Customers

Thur, 9, Feb 2009 10:00:00 CST

WebCOBRA.com Expands its Free Online Video Training for all Customers

Houston, TX - February 9, 2009 - Travis Software Corp., a market leader of Advanced Employee Benefits Software Administration, announced today the expansion of the Free Online Video Training.

In early 2008, Travis unveiled the first interactive video training for WebCOBRA.com, allowing users to receive training 24 hours a day, 7 days a week. Now, since the video training has become so popular, we have expanded it from a single video, covering the basic operation of the WebCOBRA.com system, to over 10 videos that cover areas such as:

Automated QB Log-In

Changing QB Benefit Assignments

Enrolling a QB

Rate Changes

With this expanded online training, WebCOBRA operators can choose to receive training on just one part of the system or you can go through all the chapters and receive training on the entire system.

We urge you to visit the WebCOBRA.com Video Training site to see why we are so excited about being able to provide this added benefit to your WebCOBRA subscription. You can also learn more about the Video Training by visiting the Travis Blog at http://blog.travisoft.com and viewing the video highlighting the new features of the expanded training.

About Travis Software Corp.
Travis Software Corp., based in Houston, Texas, was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the company’s COBRA administration software system, TravisCobra, and its Web-based system for COBRA, WebCOBRA.com.

Trademarks
WebCOBRA.com is a trademark of Travis Software Corp. Microsoft and SQL Server are registered trademarks of Microsoft Corporation in the United States and/or other countries.

For more information about the WebCOBRA.com Summer ’08 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Travis Software Corp. Holiday Schedule for 2009

Tues, 6, Jan 2009 10:00:00 CST

Travis Software Corp. Holiday Schedule for 2009

Houston, TX – January 6, 2009 -- Travis Software Corp will be closed in 2009 for the following holidays:

Monday, January 19th Martin Luther King Day
Friday, April 10th Good Friday
Monday, May 25th Memorial Day
Friday, July 3rd Independence Day
Monday, September 7th Labor Day
Thurs/Fri, Nov. 26-27 Thanksgiving Day and day after
Friday, December 25th Christmas Day

Travis Software Corp wishes you a Happy New Year! For more information about WebCOBRA.com, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Travis Software Releases Summer 2008 Upgrade for WebCOBRA.com

Thur, 2 Oct 2008 03:00:00 CST

Travis Software Releases Summer 2008 Upgrade for WebCOBRA.com

Houston, TX. / October 1, 2008—Travis Software Corp., a market leader of advanced employee benefits software, announced today the Summer 2008 upgrade of its WebCOBRA.com system. The new version offers more enhanced features, including a new Retiree Billing add-on module, Online Enrollment, and Document Upload.

An online Retiree Billing add-on module has been added to WebCOBRA.com, allowing administrators to track both retirees and their benefits. With the new Retiree Billing module, retirees will be able to log in online and view account, contact and payment information, as well as initiate online payments themselves. In addition, administrators will also be able to set up benefit plans based on age, salary, and years of service.

The Summer 2008 release of WebCOBRA.com simplifies the job of administering COBRA regulations by adding an online enrollment feature. Now administrators can enable qualified beneficiaries with the option to log into the system and accept their coverage with a full electronic payment, which will significantly reduce administrative paperwork .

Another major addition to WebCOBRA.com is the ability to Upload SPDs, Benefit Summaries, and Additional Notices to the system. This new feature allows users to upload important notices so they can be viewed by qualified beneficiaries and, when applicable, retirees and other plan participants who don’t have access to the same documents that active employees do.

“WebCOBRA’s latest release advances the COBRA capabilities of the system and adds Retiree Billing capabilities as well. Now, any Cobra and Retiree Billing administrator can realize the benefits of using a full-featured Web-based system to help them provide these services to their clients,” said Alan Williams, Travis Software founder and president.

The Summer ’08 Release was installed to WebCOBRA.com without any effort on the user’s part, and is now available to use. Other enhancements include: additional matrix plan types, ability to send HIPAA certificates to dependents, prorate mid-month subsidies, universal client/employer change option, and much more.

About Travis Software
Travis Software Corp., based in Houston, Texas, was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the company’s COBRA administration software system, TravisCobra, and its Web-based system for COBRA, WebCOBRA.com.

Trademarks
WebCOBRA.com is a trademark of Travis Software Corp. Microsoft and SQL Server are registered trademarks of Microsoft Corporation in the United States and/or other countries.

For more information about the WebCOBRA.com Summer ’08 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Travis Software’s WebCOBRA a Critical Tool for Marketing COBRA Administration Services

Tue, 31 August 2007 08:00:00 CST

Travis Software's WebCOBRA a Critical Tool for Marketing COBRA Administration Services

Houston, Tex. -- August 31, 2007 -- Travis Software Corp. announced that its WebCOBRA.com system has emerged as a key marketing tool for Third Party Administrators (TPAs) and COBRA Administrators. Since its arrival in 2005, the system has been utilized by more than 2,000 users, said the market leader of advanced employee benefits software administration.

"WebCOBRA has become a compelling tool in helping to market COBRA Administration Services to both new and existing clients because of its systems intuitive, "wizard-based," user interface, its real-time access by Employers and QBs, its process for generating correspondence, and its ability for users to generate custom reports," explained Alan Williams, Travis President.

The WebCOBRA system can be used by members of the employer's staff, qualified beneficiaries, and the TPA's employees. Key features include:

Employers can enter data about new QBs, check the status of their own QBs, and create ad hoc reports, which summarize the activity of their COBRA Participants, at any time.
QBs can look at their own record at any time and see their information in a real time format. They can view information such as how many days they have left to enroll or make premium payments, as well as details of the benefit plan they've been offered or in which they are enrolled. QBs can also make premium payments online.
TPA Employees have full access to the system, including the ability to generate their own custom reports at any time.

The WebCOBRA system also reduces hardware infrastructure and IT department staff involvement because the system itself is housed on Travis-owned servers and accessed via the web. All hardware and software updates are also performed by Travis.

Travis invented COBRA software in 1986, and then re-invented the system in 2005 with WebCOBRA, the web-based COBRA administration system. WebCOBRA is fully-featured, mature, and it has had 100% uptime since the original release in April 2005.

About Travis Software
Travis Software Corp. was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985, COBRA, which mandated group health continuation for the first time and created the market opportunity for the Company's first product, the TravisCobra software system. Travis is based in Houston, Texas and has over 2,000 Employers and Administrators using its COBRA, Flexible Benefit, and Premium Benefit systems. The Company has been solidly profitable each year since its founding in 1986.

For more information about the WebCOBRA.com system, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com, or visit Travis Software at www.webcobra.com.

Report Subscriptions, ACH Processing, and Payment Updates Mark Summer Upgrade of Travis Software's WebCOBRA.com

Mon, 06 August 2007 08:00:00 CST

Houston, Tex. -- August 6, 2007 -- Travis Software Corp., a market leader of Advanced Employee Benefits Software Administration, announced today the Summer 2007 upgrade of its WebCOBRA.com system. The new version offers more enhanced features, including Report Subscriptions, ACH Processing, and a Payment Schedule of Qualified Beneficiary (QB) premiums for easy review of upcoming payment amounts.

The newly enhanced version of WebCOBRA.com allows for more control over reporting capabilities. Report Subscriptions have been added, allowing users to easily email reports to clients, supervisors, co-workers and more. Users can set up subscriptions of any report in the system, for any time period, to be delivered whenever the user specifies.

Third Party Administrator users of WebCOBRA.com now have the ability to process Electronic Funds or ACH for the client/employers or carrier/sponsors in the system. Designed to allow for easier disbursement of premiums, users can process disbursements for all client/employers as well as sponsor/carriers at once, producing an ACH file in conjunction with any disbursement checks that the system may produce.

Premiums at the QB level are now easier to foresee. From the Payment and Ledger screen, users will now be able to create a Payment Schedule. This allows the user to see any upcoming premium changes due to rate changes or coverage extensions, in addition to allowing for a direct auto fill of a payment amount on the payment entry screen.

“Benefits Administrators are constantly being asked by their clients to provide more services for their COBRA beneficiaries,” says Alan H. Williams, founder and President of Travis Software Corp. “The Summer 2007 release is intended to enable administrators to do exactly that. Administrators can let participants have their COBRA premiums auto-deducted from their checking account, they can disburse premiums to Insurance Carriers via electronic check (ACH), and they can have reports automatically emails in PDF or Excel without any interaction by the user.”

The Summer '07 Release was installed to WebCOBRA.com without any interaction on the user's part, and is available to use now. WebCOBRA.com is available 24x7 and featured a service level history of 100% uptime during the last year. Other enhancements include Automated QB Payments, Bank Accounts, Correspondence Wizard and History, Mailing Labels, Correspondence Summary Report, Logout Links and much more.

About Travis Software
Travis Software Corp. was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) which mandated group health continuation for the first time and created the market opportunity for the Company's first product, the TravisCobra software system. Travis is based in Houston, Texas and has over 2,000 employers and administrators using its COBRA, Flexible Benefit and Premium Billing systems. The Company has been solidly profitable each year since its founding in 1986.

For more information about the WebCOBRA.com Summer ‘07 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Travis Software Offers Ways for Employers to Manage Rising Postal Rates

Thurs, 16 May 2007 08:00:00 CST

Houston, TX -- May 16, 2007 -- Travis Software Corp., a market leader in Advanced Employee Benefits Software Administration and provider of the WebCOBRA.com system, announced current and future software features designed to manage the rising postal rates now facing employers and third-party administrators.

“With postal rates up to 41 cents per ounce as of May 14, and with the thickness of what you mail adding to the cost of postage for the first time, managing your COBRA correspondence is more important than ever,” says Alan H. Williams, founder and President of Travis Software Corp. “Since the U.S. Department of Labor mandated that the Cobra General Notice be at least six pages and the Cobra Election Notice is sometimes as much as 20 pages long, these letters have required more postage than before.”

WebCOBRA.com includes several capabilities designed to help manage postage costs. A brief list of the features already in the system is provided below:

Duplex Printing is a standard feature in WebCOBRA's Enterprise Edition. It allows for Cobra letters to be printed on both sides of the paper with a printer capable of doing so, and can reduce costs of paper as well as postage.
The ability to email COBRA letters and forms once the Cobra Election Notice has been sent and the QB has certified that he/she would like to receive future correspondence via email is a standard capability of WebCOBRA.
The Bulk Correspondence Printing capability sorts all printed COBRA letters into zip code order, prints a barcode on the address block that is machine-readable by the Post Office, and is designed to allow for volume-based postal discounts on your COBRA letters.

“The next major release of WebCOBRA, targeted for summer 2007, is designed to reduce the number of pieces of paper printed by a system, reducing weight, thickness of the envelope and paper, toner and postage cost,” says Williams. “For instance, out of about 30 new features, one is the capability of deciding whether or not to print a separate HIPAA Certificate for each QB in a QB Group, as is done now, or combining all of the QBs in one QB Group into one HIPAA Certificate.”

WebCOBRA.com now has over 125 TPAs and as many employers using the system for COBRA administration. The system has been available over two years.

About Travis Software Travis Software Corp. was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) which mandated group health continuation for the first time and created the market opportunity for the Company's first product, the DOS-based TravisCobra software system. Travis is based in Houston, Texas and has over 2,000 employers and administrators using its COBRA, Flexible Benefit and Premium Billing systems. The Company has been solidly profitable each year since its founding in 1986.

For more information about the summer release of WebCOBRA.com, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Calendar and ToDo List Features Highlight March 2007 Upgrade of WebCOBRA.com from Travis Software

Wed, 07 Mar 2007 08:00:00 CST

Calendar and ToDo List Features Highlight March 2007 Upgrade of WebCOBRA.com from Travis Software

Houston, TX -- March 7, 2007 -- Travis Software Corp., a market leader of advanced Employee Benefits Software Administration and provider of the WebCOBRA.com system, announced the availability of WebCOBRA.com’s March ’07 upgrade. The new version offers more enhanced features, including a redesigned look, Calendar and ToDo list options.

With this release, WebCOBRA has adopted the new style of so-called Web 2.0 companies, utilizing several exciting technologies such as AJAX and JSON, with the end result a more pleasing experience for users of the system. Organizing daily tasks, meetings, and reminders just got easier with the redesigned Calendar. Users can book activities into their calendar efficiently and stay on top of important dates with recurrence and reminders. Create events, link them to QBs, Client/Employers, or Carrier/Sponsors, and the system will send reminder alerts.

Along with organizing events, reminders and tasks can easily be added to the new home-page ToDo list. Designed for ultimate usability and simplicity, tasks are easy to both add and mark off. Use the To-Do list to organize the day and manage priorities. The To-Do list provides a consolidated view of tasks, making it easy to act on the information.

"The March '07 release is centered on the idea that working on the Web should be a pleasant and productive experience," says Alan Williams, founder and President of Travis Software Corp. "Our new, softer user interface and organization tools make using WebCOBRA.com more productive and users will have a more enjoyable experience using the system."

The March '07 Release was installed to WebCOBRA.com without any interaction on the user's part, and is available to use now. WebCOBRA.com is available 24/7 and has a service level history of 100% uptime during the past two years.

About Travis Software
Travis Software Corp. was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) which mandated group health continuation for the first time and created the market opportunity for the Company's first product, the TravisCobra software system. Travis is based in Houston, Texas and has over 2,000 employers and administrators using its COBRA, Flexible Benefit and Premium Billing systems. The Company has been solidly profitable each year since its founding in 1986.

For more information about the WebCOBRA.com March '07 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

WebAPI Service and Bulk Mailing Features Highlight January Upgrade of Travis Software's WebCOBRA.com

Sun, 07 Jan 2007 08:00:00 CST

WebAPI Service and Bulk Mailing Features Highlight January Upgrade of Travis Software's WebCOBRA.com

Customizable reporting features expand program's flexibility, enable users to save time and money

Houston, TX - January 9, 2007 -- Travis Software Corp., a market leader of Advanced Employee Benefits Software Administration and provider of the WebCOBRA.com system, announced today the availability of WebCOBRA.com's January '07 upgrade. The new version offers more enhanced features, including a WebAPI service, bulk mailing and additional reports and options.

A WebAPI was added to WebCOBRA.com in the January Release which opens doors to user's data. WebCOBRA now provides an Application Programming Interface to allow customers to create real-time programs that query WebCOBRA for data or fill a local Access Database. Customers can then use this database to create custom reports.

The WebAPI uses a SOAP WebService; SOAP is short for Simple Object Access Protocol, and is designed so that multiple programming languages and operating systems can access the service. Multiple operating systems, such as Linux, UNIX, Mac OSX, and Windows can create reports and applications.

To get started, developers can join devcenter.webcobra.com, a community website where users can download free code, ask questions, and share answers. Devcenter's code is released under the BSD license, and is free of charge. Developers can use this code for their own internal applications or release commercial applications.

The January '07 upgrade also gives Third Party Administrator users of WebCOBRA.com the ability to optimize their correspondence for Bulk Mailing. Designed to sort correspondence by zip code to save on postage, Travis Software is also offering a Travis Bulk Mail Service if users wish to outsource their correspondence mailing. Users can also save time and money by utilizing the bulk mailing service which will duplex print, sort, insert OMR tick marks and potentially mail correspondence with the touch of a button.

"The January '07 release is intended to help administrators maximize their time, along with letting them grab every bit of information the WebCOBRA system houses," says Alan H. Williams, founder and President of Travis Software Corp. "Whether it's saving on postage with Bulk Mailing or creating real time reports for their clients using the new WebAPI feature, more and more of WebCOBRA.com can be done instantly, effortlessly, and on demand."

The January '07 Release was installed to WebCOBRA.com without any interaction on the user's part, and is available to use now. WebCOBRA.com is available 24x7 and has a service level history of 100% uptime during the past two years. Other enhancements include Rate Expiration reminders, Test Check Printing, Tracking Dependents by age and much more.

About Travis Software
Travis Software Corp. was founded in June 1986, shortly after the enactment of the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) which mandated group health continuation for the first time and created the market opportunity for the Company's first product, the TravisCobra software system. Travis is based in Houston, Texas and has over 2,000 employers and administrators using its COBRA, Flexible Benefit and Premium Billing systems. The Company has been solidly profitable each year since its founding in 1986.

For more information about the WebCOBRA.com January '07 release, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.

Travis Software Corp. Holiday Schedule for 2007

Tue, 02 Jan 2007 08:00:00 CST

Travis Software Corp. Holiday Schedule for 2007

Houston, TX – January 2, 2007 -- Travis Software Corp will be closed in 2007 for the following holidays:

Monday, January 15th Martin Luther King Day
Monday, February 19th President's Day
Friday, April 6th Good Friday
Monday, May 28th Memorial Day
Wednesday, July 4th Independence Day
Monday, September 3rd Labor Day
Thurs/Fri, Nov. 22-23 Thanksgiving Day and day after
Mon/Tues Dec. 24-25 Christmas Eve and Christmas

Recent COBRA Administrative Requirement Changes

Mon, 23 Oct 2006 08:00:00 CST

Recent COBRA Administrative Requirement Changes

Houston, TX -- October 23, 2006 -- As part of our ongoing effort to keep our customers informed of changes to COBRA and other laws, regulations and court decisions that affect our TravisCobra and WebCOBRA.com systems and may affect the way you administer group health continuation, we want to let you know of two new items that recently came to light.

Item #1 -- The first is IRS Information Letter 2006-0042, which was issued to clarify whether payments made to a former employee to pay or help pay for his/her COBRA premiums represent taxable income to the employee. In this Letter, the IRS keyed their decision on whether or not the former employee is given "complete control" over the disposition of the funds used to pay for the COBRA coverage.

If the employer makes the payment to the employee under an understanding or assumption that the funds will be used to purchase health insurance, without the employer verifying that the funds are so used or having control over the purchase, then the monies paid to the former employee are wages subject to FICA taxes.

If, on the other hand, the employer makes the payments directly to the insurer or self-funded trustee, then the payments are not income to the employee. This is true even if the employer sends the money through the employee to the insurer, as long as the right of disposition of the funds by the employee is "not unlimited."

We have seen an increased usage of the "Subsidy" features in TravisCobra and WebCOBRA.com during the past several years, so this Information Letter was of interest to us when we first learned of it. In checking with many of our customers, payments of full or partial COBRA premiums made by employers appear to be, in most cases, made directly from the employer to the insurer or plan trustee/TPA, which will not create any taxable income for the employee. However, if premium payments are being made directly to the employee by the employer with no control or verification that they are being used to pay premiums, a taxable event may be occurring.

Since most of the subsidized premiums we see users enter on our systems do not appear to be taxable, we're going to add a feature to TravisCobra and WebCOBRA.com that will allow administrators to designate a particular subsidy payment as taxable, but will not require any new input fields to be completed if the payment is not taxable. Also a new report will be added summarizing the apparent taxable subsidy payments.

Item #2 - In an example of another state government expanding their mandated continuation regulation, the State of Tennessee, which before now only mandated continuation for three or six months on insured plans offered by employers with fewer than 20 employees, has enacted a new law effective January 1, 2007 that applies to all group health policyholders with insurance policies governed by the laws of Tennessee, regardless of employer size. The new law, known as Senate Bill 1091, requires a new notice be sent separately to divorced or separated spouses, and saying the notice must be sent via Certified Mail!

Tennessee will become the 13th state to have laws that either require administrators to perform specific actions not required by Federal law, or require administrators to extend continuation coverage past the term specified by Federal law.

The Tennessee law is interesting because it appears to place responsibility for notifying a divorcing spouse who will be losing group health coverage onto the other party to the divorce - the person whose health coverage will not terminate because of the divorce or legal separation. Under Federal COBRA law, the responsibility to notify the administrator of the divorce falls generally on the person who loses coverage. In fact, COBRA specifically says that if the employer or administrator is not notified of the divorce/separation within sixty days after it occurs, the offer of group health continuation can be refused.

The law is also interesting because it requires the new notice to be sent via certified mail to the last known address of the spouse. The certified mail requirement not only is a first, but contravenes previous Federal case law regarding how notices may be sent to satisfy COBRA requirements.

The new special notice may present new challenges to COBRA administrators because the law requires that it "Every insured or policy holder of a group policy of accident and sickness insurance offered for sale in this state (TN) which provides coverage for hospital or medical expenses that also provides coverage to the spouse of the insured, shall provide at least thirty (30) days prior notice of the termination of coverage to the covered spouse when a divorce, a legal separation, or other separation, between the insured and the covered spouse has occurred or has been filed for by the husband or wife or such divorce or separation has become final."

The law specifically mentions that it applies to COBRA coverage and also provides that the divorce court judge shall determine if the notice requirement has been met prior to issuing a decree of divorce. It also charges the "administrative office of the courts" to develop a model notice reflecting the provisions of the new law.

So what does this mean to COBRA administrators with plans sitused in Tennessee? Because the new law is somewhat vague in its requirements and timing, it raises more questions than it answers. Some of the questions are:

Will divorce attorneys include the notice to the spouse as part of the filing for divorce, so that the "30-day prior to loss of coverage" notice requirement is met?
If so, does that relieve COBRA administrators of the need to send this new notice?
If not, and COBRA administrators are looked to as the sender of the newly-required notice, how are they going to know to send it; i.e. who will notify them, and is the notice now going to have to be sent at least thirty days prior to loss of coverage?
If the notice is sent less than thirty days prior to loss of coverage, is coverage to be extended until the 30-day period has expired? If so, who pays for that coverage after the COBRA qualifying event date but prior to the new loss of coverage date? These and other questions were posed to the Tennessee Department of Commerce and Insurance on October 11th. Their representatives could not answer any of these or other questions we posed, saying that clarifications had not yet been issued.

We will modify both TravisCobra and WebCOBRA.com to meet whatever requirements surface from the new Tennessee law. We may need to add the Model Notice to the systems if one is issued by the State, and other changes may also be needed. At present the system can, of course, print notices to a divorcing spouse, so in the absence of clarification from the Tennessee state government, we are not embarking on any modifications at this time.

Administrators who have plans based in Tennessee may want to take notice of the law when it goes into effect on January 1, 2007, particularly if COBRA administrators are looked to for sending the notice via certified mail, and particularly if it becomes the responsibility of their employees to notify them of the existence of a divorce, rather than being able to wait on the spouse who lost coverage doing so within 60 days.

We will keep you informed as we learn more about the new Tennessee law's application, and as we add the capability concerning taxable subsidy payments to both TravisCobra and WebCOBRA.com

For more information about WebCOBRA.com, or any other products that Travis Software provides, please contact Travis Marketing at (281) 496-3737, email Travis Software at webcobra.marketing@travisoft.com or visit Travis Software at www.webcobra.com.