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.