BCBS has finally responded to the mini cobra section of the new law. This is still a very confusing section of the law.

Just make sure that letters are going out to your ex employees that were on your health plan as of 9-1-08.

Proposed Regulation
Effective April 1, 2009

114.5 CMR DIVISION OF HEALTH CARE FINANCE AND POLICY
114.5 CMR 18.00: HEALTH INSURANCE RESPONSIBILITY DISCLOSURE

Sections

18.01 General Provisions
18.02 Definitions
18.03 Employer HIRD Form
18.04 Employee HIRD Form
18.05 Other Provisions
18.01 General Provisions(1) Scope and Purpose.

The stimulus package contained a provision for the payment of Cobra benefits for the involuntarily terminated employee commonly thought of as an employee that was laid off, this quickly changed to anyone that would have been given an offer of Cobra benefits.

The Fair Share Contribution. Filing, Audits, Costs,Terms, Comments.
 
The on line filing. requires you to have the following information ready. Total hours worked at your company.  Remember to count salary hours as 500 per quarter. You can deduct employee hours when the employee  worked less than 150 hours in that quarter (providing the employee hours in the prior 3 quarters would not total more than 150) You can also deduct the hours for any employee that worked over 500.