PEER CONNECTIONS
Join the Human Resources Discussion Group to connect with peers from fellow MBA member banks. Sessions focus on key HR topics such as compliance, employee benefits, recruiting, talent development, and other issues that matter most to your bank.
Meetings are informal and collaborative, creating space for open discussion and practical peer exchange. Members are welcome to attend as often as their schedules allow, and each session is designed to stand on its own while contributing to an ongoing conversation.
Each month, we circulate a brief survey featuring questions and topics submitted by members. If you have a question, topic, or speaker suggestion for group, feel free to send it my way at any time. I would be happy to include it in an upcoming survey. Click here to email me.
Survey results are shared monthly via email and posted on our website for easy access.
View the February survey results (click each question to reveal the responses)
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Chad Pook, 2/21/2025 10:00 AM
COBRA HRA Example Follow-up:
Determining HRA rates on COBRA can be tricky. There are two methods the client can use to determine the COBRA rate:
• Past Cost Method: The employer looks at the total claims reimbursed by the HRA during a 12-month “determination period. For example, assume that employees have a $1,200 HRA plan ($100 employer contribution per month), but over the plan’s lifetime only 50% of the total benefits have been claimed and paid. In this instance, the COBRA rate is $1,200 x 50% = $600. You can add 2% to the premium for COBRA administration fees, resulting in an annual rate of $612 or a monthly premium of $51.
• Actuarial Determination Method: The actuarial method is for first time plans which require the actuary or administrator to make a reasonable estimate of the cost of providing HRA coverage (reasonable estimate of the Employer’s exposure or HRA utilization plus administrative fees).
COBRA regulations does not determine which method has to be used. When either method is used, the resulting COBRA premiums should be based on total plan cost, not on the individual HRA balance of a participant electing COBRA.
If they are unsure how to calculate the rates, I would recommend the client consult with actuary to help determine the correct calculations. HealthEquity cannot determine this for the client, even if we are their current HRA administrator. We can provide utilization numbers on the plan that can help them determine the rate, only.
As far as how the client should offer the HRA under COBRA, they need to offer it the same way they would offer an active employee. For example, if the employer’s plan design states in order to enroll in the HRA plan, you must elect the medical plan, then the same rules should apply to a COBRA member. In this scenario, if these are presented as two separate plans to the active employee, they should do the same for the COBRA member. They would want to attach a rate to the HRA plan, using one of the methods above to determine the rate. HealthEquity can set a rule that states in order to elect HRA, they must elect the medical plan as well, under COBRA.
Chad Pook, 2/21/2025 10:03 AM
Dodie was also kind enough to send me an analysis of the recent Executive Order on “Ending Illegal Discrimination and Restoring Merit-Based Opportunity” by the American Bankers Association which I've included in the downloadable materials.
Chad Pook, 2/21/2025 10:26 AM
Massachusetts Pay
Transparency Law Update
via
Zoom Platform
on
March 12
from
10:00 AM - 11:30 AM
The Massachusetts Bankers Association is proud to partner with Morgan, Brown & Joy, LLP to present an update on the new Massachusetts pay transparency law and other hot button employment law topics. Sign up to hear directly from Morgan, Brown & Joy, LLP about the law and its requirements, emerging guidance and how you can be prepared for this and other important legal issues.
What Will You Learn:
• Massachusetts Pay Transparency Law,
• Navigating Emerging Employment Law Issues,
• And MORE!
Who Should Attend? HR Officers, Senior Management, and anyone who manages payroll
https://www.massbankers.org/Education-Training/Event/sessionaltcd/PTLE25