Pete’s Pumpkin Patch has outsourced their COBRA to Xcellent Benefit Administrators (XBA) for the last four years.  By all accounts it has been an ‘excellent’ relationship for Pete’s Pumpkin Patch and their HR Manager, Lori Wright. 

On December 12th, Jessica Whimple terminated employment with Pete’s Pumpkin Patch.  Lori Wright logged into XBA’s Client Portal and entered Jessica’s qualifying event information.  XBA then promptly sent Jessica her COBRA specific rights election notice which communicated, among other things, the following information:
- First Day of COBRA - January 1st
- Medical - Family coverage - $600 per month
- Dental - Family coverage - $150 per month
Jessica elected to continue all benefits at current coverage levels and made her first three months of premium payments. 

Jessica’s April premium payment was received by XBA on April 20th for $600 with no accompanying information about why her payment was less than the total amount due. 

XBA’s COBRA software system allows for ‘cherry picking’ of premium payments across different insurance plans (also known as ‘manual allocation of payments to premiums’).  Because of this functionality, XBA made the decision to apply the full $600 towards the dental premium for April, May, June and July.  On May 1st, XBA COBRA system terminated the medical plan for Jessica and sent a termination of COBRA rights to her medical carrier.

The Problem
Regardless of the decision made by XBA on how to apply Jessica’s April premium payment, they would ultimately be ‘guessing’.  For example, XBA could have applied the $600 for one month of medical or for four months of dental insurance.  Also, Jessica may have forgotten to include a note indicating that she intended to drop her spouse from the medical plan or drop family coverage for the dental.  The number of possible permutations is almost limitless and it is not up to XBA to ‘guess’ on how to apply Jessica’s premium payment. 

Regardless of the decision made by XBA on ‘cherry picking’ payments, we can safely assume they would be immediately wrong.  How in the world could XBA interpret the intentions of Jessica Whimple?

The Better Solution
XBA should accept the $600 and post it to her record.  The COBRA system used by XBA should record the partial payment, apply any insignificant premium payment calculations, and send the appropriate letter informing Jessica of her short payment.  If Jessica fails to pay the full $750 by the end of the April grace period, her COBRA rights for all plans should be terminated.  This is the safest course of action for XBA and Pete’s Pumpkin Patch since Jessica was silent on her exact intentions. 

We know of some administrators who would take it upon themselves to ‘reach out’ to Jessica and inquire about how to apply the premium.  It seems to us that this action could make sense if XBA’s enrolled COBRA population was small AND XBA had a current telephone number for Jessica AND could make contact with her before the end of the April grace period.  However, the overhead associated with this process is substantial and opens XBA to added exposure.  What happens if XBA forgets to make the call?  What if XBA does not have a working phone number or is unable to contact Jessica before the end of her grace period?  The burden to determine how to apply the premium payment unnecessarily shifted from the Qualified Beneficiary to XBA.

Administrators must always watch out for activities that create an ever-expanding liability circle.  For example, sending a ‘return receipt required’ letter to a Qualified Beneficiary widens the liability circle.  If the ‘return receipt required’ document is returned unsigned, the administrator now has proof the letter was not received and must act upon this knowledge.  If the administrator had simply sent a letter first class with proof of mail, the liability circle would not have been widened.  The same logic applies to ‘cherry picking’ premium payments.  By making arbitrary decisions on behalf of the Qualified Beneficiary will expand your liability circle and open the company up to unnecessary risk exposure.  

Do these questions and phrases sound familiar? 

• “I tried to go get my prescription and it was denied.  I know I elected and paid for my COBRA why are you denying my medication?”
• “I received a termination letter but I sent in payment, why are you terminating me?”
• “I got this letter and I have no idea what it means, why are these so confusing?”
• “I just terminated from my employer today, where is my COBRA paperwork?”
• “I am terminated and want to talk with your supervisor NOW”

If you are familiar with these phrases and questions you are also familiar with how difficult it can be to handle phone calls from COBRA participants.  Let’s face it, being unemployed and paying the high cost of a COBRA premium is not easy and is something no one wants to experience.  Learning how to provide excellent customer service will not only help you as the customer service representative better understand your caller and diffuse what could be a bad situation, but it will also ease the tension from the COBRA participant.  Great customer service skills require talent as well as time and effort.  Creating an environment where you have the tools and training to do the best work can be done.  Employing various training and coaching, will teach employees the company standards and how to stay sharp.

There are a number of great companies who teach phone skills to customer service representatives (CSR) across all industries.  In the role as a CSR for a COBRA administrator, you have a unique opportunity to not only help the individual understand their rights under COBRA, but also help ensure they maintain group health coverage during their life changing event.  At our prior company, we employed the services of one such company and found the techniques to be useful, but we also spent a lot of time configuring their techniques to our specific industry and type of call our staff managed.

Listed below are several ‘customer courting etiquettes’ to get you started:

• Greet each call with a warm, sincere smile on your face.  The caller can hear if you are frowning.
• Be energetic and engaged in the call.  If you are apathetic, this will only make matters worse.  Manage expectations and only promise to do something if it is in your power to do so 
• Listen without interrupting.  Sometimes allowing the caller to ‘blow-off’ steam is the quickest path to having a productive call which leads to an issue resolution. 
• Remember, the caller is upset at the position they find themselves in, not at your personally.
• Respond with appropriate emotion (show enthusiasm or empathy)
• Be polite and kind (genuine politeness is rare these days – a well timed “please” or “thank you” goes a long way). Appreciate a person’s time and respect it as valuable.  Remember, it could be spent with a competitor.
• Make the other person feel smart, important and good (even if they make mistakes or ask silly questions)
• Avoid being a “parent” (authoritative, condescending)
• Never accuse the person of making a mistake
• Never blame the person for the current situation in which they find themselves
• If your answer is not what the caller is wanting to hear, be firm, polite and try not to diffuse an emotional call with an apology if there is simply nothing that can be done to resolve the situation.
• Try to avoid using accusatory words like ‘YOU did not enroll on time’ or ‘YOU did not send in the payment in time’.  Rather shift the conversation to something neutral.  Try saying “the enrollment form was not postmarked within the federal guidelines for enrollment” or “the postmark date on the envelope for the payment was not within the federal guidelines for a timely payment”.

The continued success and growth of a company greatly depends upon the level of service provided.  As a COBRA administrator, you have many customers to manage.  Consider in many relationships a CSR must manage the broker, the employer, the carrier and the COBRA participant who are all stakeholders in the quality of the outcome of the customer service delivered. 

A final note, we operated under the mantra “it it wasn’t written down, it never happened”.  Be sure to document all your calls in clear, concise, and accurate notes.  This will prove to be very useful to you, your company, and all the stakeholders.

As an administrator, if you hadn’t discovered already, Legacy or Takeover QBs is the most labor intensive piece of acquiring a new client.  A legacy QB is defined as a member who has already been offered COBRA or sent their Specific Rights notice through another administrator.  They are a member who have been offered COBRA and are in one of three stages of the election process:

·         Pending – Offered COBRA, still in their 60-day election period

·         Pending Received – Offered COBRA, election form was received with no payment, still in their 45-day initial premium payment period

·         Enrolled – Offered COBRA, elected, and is now in their subsequent payment grace periods

With these three stages that a legacy QB could potentially be in, gathering information to properly enter the member is crucial.  To ensure you gather the proper information required to enter your QBs, you should review the data that is required by your COBRA software.  If you do not want to manually enter this takeover information, you can also obtain Import File Specifications that will allow you to load the participants via a file upload.

Typically the information that is essential to having is the Specific Rights notice date, Postmark Date of Election (if QB has elected), and the Next Month Owed (if QB has elected).  These three dates are what make up the above three stages and are needed in order to enter and notify the legacy QB properly.  Asking the previous administrator for this information is not uncommon or out of the question.  A TPA administering COBRA should have all this information easily accessible in their current COBRA software. 

Obtaining the above information for legacy QBs should begin in the early stages of the new client acquisition.  These QBs tend to get lost between the two administrators and are often notified late regarding the transition.  It is important to designate additional time and efforts to ensuring a smooth transition for the acquired COBRA members.

When people ask me what I do for a living, I used to tell them I run a Client Service department for a COBRA and Direct Billing administrator.  Invariably they would say “snakes”?  With a gleam in my eye, I would launch into a 20,000 foot perspective of what COBRA is and how important this regulation is to employers and employees.  About 90 seconds into my mini education session my listener’s eyes would begin to gloss over and I soon began to realize I should stick to telling people the following, “COBRA, it’s an insurance thing.”

My name is Kelly Robinson and I have worked in COBRA and Direct Billing administration since February 2001.  I have lived and breathed COBRA for the past seven years starting as a Client Service Specialist and moving up to Manager of Client Services.  I managed a great staff responsible for over 2,500 employer clients and $88MM in COBRA premiums.  Since COBRA deals directly with healthcare (and in this day and age healthcare is not a subject to be taken lightly) I made it my personal goal to continue to grow my knowledge of COBRA, hence I am a COBRA Geek.  Additionally, I have always strived to build the best trained staff in COBRA and Direct Billing administration that always ‘delivered more than expected, faster than requested’.  My clients told me we were succeeding on this simple mandate and this has been the most motivating thing in my professional life.

Today, I wear a new hat.  I no longer support employer clients, but rather my team and I serve some of the nation’s largest, most respected administration firms.  Within Benaissance, my team and I are now helping our customers transform their operations. Switching gears a little bit I now have a great opportunity to delve into the software world.  Whoever said that a person whose main focus is customer service can’t be technical doesn’t do what I do.  Listening to our customers, developing functional specifications, championing new features, and forcing Benaissance to stay on the leading edge is a thrill for me.

I hope this blog makes the other COBRA Geeks of the world smile and chuckle because they know from where I speak.  As crazy as it sounds I am excited to write about my COBRA adventures and look forward to sharing my experiences and knowledge with the rest of the COBRA Geeks.