COBRA Premium for Self-Funded Bundled Plan

[Guest Jeff Kropp]

An employer automatically enrolls it employees in its self-funded group health plan. The plan is a bundled plan that offers health, dental, and vision coverage, and employees are not charged a premium. Now that employers no longer are required to offer core coverage only, can the employer charge one premium for COBRA coverage. Would the answer change if the plan was not bundled (i.e., separate plan documents, etc.)? My thought is that one premium could be charged, since employees and actives are treated the same (i.e., they have automatic coverage in all of the plans).

Any thoughts are appreciated (as there is no clear DOL/IRS guidance on this issue)?

[Guest robkt]

Jeff,

I have a self-funded plan bundled for premium purposes. There are separate plan documents (SPD's) for 1.hospital 2. major med, RX & dental 3.life 4. short term disability 5. long term disability and 6. vision

What is interesting about this group is there are no pre-cert or managed care devices in place - nor do we use a drug card.....and we are doing super. 155 employees and 20 retirees and 4 COBRA - total plan cost $700,000.

Hope this helps you out.

RobKT