COBRA Payments

[Guest AHayhow]

We are getting ready to administer COBRA for one of our clients. As part of the agreement, we will accept the COBRA premium payments and deposit them into a checking account. At the end of each month, using reports generated from our COBRA Admin system we will cut the employer group a check equal to the amount of COBRA premium payments received.

My question.... are there any regulations/laws that require these funds to be deposited into a special type of checking account? Also, if we continue to add clients to our COBRA Admin Department, do we have to establish a separate checking account for all clients (or can the funds be co-mingled)? Thanks