May 27, 2021
Kaiser Permanente has announced a process for facilitating the new APR requirements based on how federal COBRA and/or Cal-COBRA is currently billed.
Groups Billed Federal COBRA and Kaiser Billed Cal-COBRA
The employer, or third-party administrator, administers its own federal COBRA health coverage. The employer's Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA; Kaiser bills members directly.
Employer Responsibilities
For an employer's federal COBRA population, the employer is responsible for:
- Sending required ARP notices to their employees.
- Paying COBRA premiums to Kaiser for assistance eligible individuals (AEIs) based on bills received.
- Claiming the payroll tax credit.
For an employer's Cal-COBRA population, the employer is responsible for:
- Confirming that an individual is assistance eligible.
- Notifying Kaiser if an AEI has a change in eligibility.
Kaiser Responsibilities
Kaiser has no responsibilities for the employer's federal COBRA population.
For an employer's Cal-COBRA population, Kaiser will:
- Send the ARP notices to the employers current Cal-COBRA population and include the model summary.
- Reach out to the employer to confirm individuals are assistance eligible.
- Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021.
- Claim the payroll tax credit for Cal-COBRA AEIs.
Kaiser Billed Federal COBRA and Cal-COBRA
Kaiser bills the member directly for federal COBRA health coverage and any Cal-COBRA mandated coverage. The employer's Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA.
Employer Responsibilities
For an employer's federal COBRA population, the employer is responsible for:
- Sending required ARP notices to their employees.
- Informing Kaiser of AEIs by filling out the supplemental reporting template on account.kp.org.
- Paying COBRA premiums to Kaiser for AEIs based on bills received.
- Claiming the payroll tax credit.
For an employer's Cal-COBRA population, the employer is responsible for:
- Confirming that an individual is assistance eligible.
- Notifying Kaiser if an AEI has a change in eligibility.
Kaiser Responsibilities
For an employer's federal COBRA population, once Kaiser receives the supplemental reporting template from the employer, Kaiser will:
- Transfer AEIs from direct billed to group billed.
- Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021.
- Bill the employer retroactively for AEs for coverage beginning on or after April 1, 2021.
For an employer's Cal-COBRA population, Kaiser will:
- Send the ARP notices to the employers current Cal-COBRA population and include the model summary.
- Reach out to the employer to confirm individuals are assistance eligible.
- Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021.
- Claim the payroll tax credit for Cal-COBRA AEIs.
Kaiser Billed Cal-COBRA
The employer is subject to Cal-COBRA and Kaiser directly bills members.
Employer Responsibilities
For an employer's federal COBRA population, the employer is responsible for:
- Confirming that an individual is assistance eligible.
- Notifying Kaiser if an AEI has a change in eligibility.
Kaiser Responsibilities
Kaiser will:
- Send the ARP notices to the employers current Cal-COBRA population and include the model summary.
- Reach out to the employer to confirm individuals are assistance eligible.
- Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021.
- Claim the payroll tax credit for Cal-COBRA AEIs.
Please visit our dedicated ARPA page, where you can see the stance of all carriers and check for the most up-to-date information.
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