COBRA Subsidy Final (state and 125 Plans)

[somarco]

FWIW, here is the Treasury notice.

Read Q&A 27.

No doubt there is, and will continue to be, a lot of confusion. Predictable given the fact that Congress and most of Washington is run by lawyers, not benefit managers. And let's not forget that no one read the bill before signing it into law.

 

[Dave020]

Thanks Bob, for that link. 27 and 29 help clarify it, I think.

If there is a FSA combined with a 125 plan, then the subsidy is exempt, yet if there is a FSA combined with HRA, it is not exempt?

For you guys and gals who write larger groups, which is more common? My groups are mostly HSA (spousal) and with the exception of BSCA any FSA/125/HRA are strictly prohibited (CA Small Group) so I never see this.

 

[djs]

I must still be misreading this, but then, that would make me eligible to be a senator

As I read it, this is referring only to the spending account portion of the FSA, not the plan itself. So if I was putting $1000 into my spending account under my cafeteria plan, this would not be eligible for subsidy. The health plan itself would still be eligible for subsidy though.

Of course, this would make sense, since I don't think the FSA deposits were ever eligible for cobra anyway.

Dan

 

[Dave020]

I have seen situations where the COBRA beneficiary has had the FSA money pulled back out of the FSA (funded with credit card) and the beneficiary has to reimburse for service.
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FWIW, here is the Treasury notice.

Read Q&A 27.

No doubt there is, and will continue to be, a lot of confusion. Predictable given the fact that Congress and most of Washington is run by lawyers, not benefit managers. And let's not forget that no one read the bill before signing it into law.

I have to ask since its on CNN today. Bob, have you ever had a "ghetto burger" at Ann's Snack Bar in Atlanta? Supposed to be one of the best in the USA. She is going to sell soon and will be selling the recipe separately.

 

[somarco]

I have no idea where Ann's Snack Bar is but a ghetto burger doesn't sound too appetizing.

Looking it up, I don't think I will be eating there any time soon.

I have been known to frequent the Varsity from time to time. "what'll ya have, what'll ya have?"

Two naked dogs walking with rings and an FO.

As for the FSA thing, I have a buddy checking some of his sources as well. To me, the Treasury notice is ambiguous at best. Ignoring the dental, vision & mini-med part I can see how it can be interpreted two ways.

1) If you have an FSA the cash portion (covering OOP for deductibles, coinsurance, etc.) is not included in the subsidy. That should be a given.

but I can also see this . . .

2) If your group major med plan is under an FSA you are not entitled to the subsidy.

If #2 is accurate, then someone messed up big time. But then, we are dealing with attorneys . . .

 

[Dave020]

Five tasty burger joints worth visiting - CNN.com

Even has a picture of the "ghetto burger"

 

[somarco]

The burger may be good. You don't know that part of town. I do. Not the area you want to be once the sun goes down . . . or comes up.