1. What is the amount of the HRA fund that the COBRA spouse would have available to them?

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1 BorgWarner HRA Account Reference Guide HRA Life Status Change Scenarios BorgWarner has elected to prorate HRA balances based on a monthly calculation. The diagram below provides unique examples of how the fund will be administered based on various life status situations. All scenarios below are based on a plan that provides a $750 individual HRA fund and a $1,500 family HRA fund. It s important to note that when you encounter a COBRA situation, Cobra law applies to this calculation. The regulations indicate that an individual must have the same coverage in place the day after a life status event as they do the day before. This has a definite impact on how the HRA calculation occurs when Cobra is elected. Here s a quick example: When an HRA member goes on COBRA they will get their own fund equal to the amount of the fund balance they had prior to the COBRA event. So, if the family HRA balance was $200 when the COBRA event occurs, then the COBRA person would get a fund for $200 and should be moved to the Single benefit option. Another example is -- If the family had a fund balance amount of $1500 when the event occurred, then that COBRA individual would be set up with the $1500 fund and moved under the Single benefit option. At renewal, the COBRA person would get the SINGLE participant employer contribution HRA fund amount since they are a single member. Outlined below are a number of other mid-year status changes that affect the administration of the HRA account funding. Scenario Summary Scenario Details Question(s) Reply Divorce: Employee + Spouse initially enroll as "family", but divorce 2. What is the amount of the HRA funds that the COBRA spouse would mid-year. All HRA funds are used have available to them, as of date of divorce. given that they are set up under their own SSN? Choice Fund HRA and includes their spouse as a dependent. The employer provides them with a $1500 family HRA fund. The spouse uses all $1500 of the HRA funds. Later in the same plan year, the employee removes their spouse as a dependent due to divorce. The divorced spouse continues their coverage under COBRA under their own SSN. 1. As of the COBRA qualifying event, the $1500 HRA fund had been completely used up. Therefore, both the employee and the COBRA spouse will not have access to any HRA funds. The client's eligibility file will identify the spouse as a COBRA "single" continuant and will match them to the HRA balance they had in effect as of the date of the qualifying event. In this case, that HRA fund amount was zero

2 Divorce: Employee + Spouse initially enroll as "family", but divorce mid-year. Portion of HRA funds were used as of date of divorce. Choice Fund HRA and includes their spouse as a dependent. The employer provides them with a $1500 family HRA fund. The spouse uses $1000 of the HRA funds. Later in the same plan year, the employee removes their spouse as a dependent due to divorce. The divorced spouse continues their coverage under COBRA under their own SSN. 1. What is the amount of the HRA fund that the COBRA spouse would have available to them? 2. Does the employee still have $500 in HRA funds available to them? 3. If CIGNA receives a bill for $3,000 for the employee, and the incurral date is prior to the divorce date, how does the system apply the correct HRA amount to the claim? 1. The COBRA spouse will be set up as an enrollee under "single" status and will have access to the remaining $500 HRA fund they had access to prior to the qualifying event. 2. Yes. The employee's goal amount does not change after their spouse goes on COBRA. The employee will still have $500 in HRA funds remaining after the qualifying event ($1500 original goal amount - $1000 used). 3. The claim system looks at the date of service for the claim and processes the claim under the HDHP. After the claim is adjudicated, and after the member responsibility is determined, the claim will auto-forward to the HRA. The balance available in the HRA fund as of the date the claim is processed will then be used. Divorce: Employee + family enroll. All HRA funds are still available as of date of divorce. Employment Termination, Any time throughout the plan year Choice Fund and includes their spouse and children as dependents. The family is eligible for a $1500 HRA fund. The employee removes spouse due to divorce, but keeps the children on the HDHP. At the time of the qualifying event, the HRA balance is $1500. The divorced spouse continues their coverage under COBRA. Termination of employment 1. What HRA fund amounts are available to the employee and children? 2. What HRA fund amounts are available to the divorced spouse. How does employment termination impact HRA fund amounts? 1. The employee and family would have access to a $1500 HRA fund. 2. The COBRA spouse would also have access to a separate $1500 HRA fund. Unused HRA funds remain available for the employer determined HRA run out period, to pay claims incurred prior to employee's termination for those individuals who do not elect COBRA. After the run out period

3 expires, any unused HRA funds revert back to the employer. Employment termination, with subsequent rehire Coverage tier change: Employee with family coverage year one elects employee only coverage year two Employee enrolls in CIGNA Choice Fund HRA family coverage and has a $1500 HRA fund. Employee uses $1000 of the HRA fund and has $500 left in their fund. They then terminate employment and go on COBRA. Employee later that year is rehired and re-enrolls in the same plan. Employee enrolls in CIGNA Choice Fund HRA with family coverage in 2007, and has $1500 HRA fund available. Employee uses $500 of the fund by the end of 2007, leaving $1000 to carryover to the following year. In year two, the employee selects employee - only coverage. How do CIGNA's systems handle each of these events? What HRA fund amount is the employee eligible for upon re-hire? What amounts will be available to the employee in year two? If the individual elects to continue coverage under the same plan they had prior to termination, they would elect COBRA and their HRA fund amount available to them prior to the qualifying event (employment termination) would remain unchanged. Each event is treated as a separately. When the employee initially enrolls in CIGNA Choice Fund HRA, they are treated as a new enrollee. When the employee terminates employment and goes on COBRA, they are set up on COBRA, and in the example provided, would have a $500 HRA fund available to them when they move to COBRA. If the employee is then re-hired, he would be set up as a brand new hire. The HRA fund amount available to the employee as a new hire would be prorated based on the month the rehire occurs. The employee would carry over the full amount of HRA funds remaining at the end of the plan year. The employee would have access to the $1000 that rolled over and the new fund amount from the employer as of 01/01/08 for employee only coverage. Coverage tier change midyear: Due to marriage between employees working for same employer Employee enrolls in HRA and covers his children, but has no spouse. Employee is provided with a $1500 family HRA fund. Employee then marries an individual who works for the same employer. The new spouse at the time of marriage had $750 in "single" HRA funds available to What happens to the $750 the new spouse had available under her own HRA plan? The $750 the spouse had prior to marriage would not move or be added to the new plan the spouse is joining. The $750 would be available under her terminated file for claim payment through the employer selected claim runout period for claims incurred during her effective

4 Gap in HRA coverage her. The employee adds new spouse to his plan, and spouse cancels her plan. Employee elects HRA and at end of year one has an HRA balance remaining for carryover. In year two the employee elects PPO coverage. In year three, the employee goes back to HRA. What happens to the HRA carryover balance from year one? What happens when employee is re-enrolled in CIGNA Choice Fund in year three, after a 1 year gap in CIGNA Choice Fund HRA enrollment? period prior to the marriage. The new spouse would have access to the amount of HRA funds the employee has available in their HRA fund as of the date the spouse is added as a dependent under the family plan. The unused HRA balance from year one would remain available during year two, but only to fund year one run out claims from the HDHP (for dates of service from 1/1 through 12/31 of year one). After the run out period ends, any unused HRA funds would revert back to the employer. In year three, the employee would be treated as a new CIGNA Choice Fund HRA enrollee. Adding dependents mid-year- New Hire, Mid-year Employee initially enrolls for employee-only HRA and is provided with a $750 HRA fund. Employee gets married and adds spouse as a dependent in March. Assume that the employee has not spend any of their HRA funds. An employee is hired as a new employee mid year, on 7/1/07. How does CIGNA calculate the new HRA fund? What HRA fund amounts will be available to the employee if they enroll in employee only coverage? What if they enroll in family coverage? Note that if there is a break in enrollment with the CIGNA Choice Fund plan years, no HRA funds will carry over into future years. With a life status change, the HRA fund amounts are pro-rated based on the date of the life status change. In this example, the family HRA amount is $1500. That amount is prorated and the new HRA amount becomes $1,250. ($1,500 divided by 12 months = $125 x 10 months = $1,250). The new hire is set up with the HRA amount for their coverage tier, adjusted based on the date of hire. The HRA amount is prorated on a monthly basis. With a hire date of 7/1/07, this employee would receive six months of the HRA fund based on the coverage tier they enroll in (employee only or family coverage).

5 Death of Employee Employee enrolls in HRA and then passes away mid plan year. How does an employee's death impact available HRA balances and how would dependents who elect COBRA maintain access to HRA funds? Any unused HRA funds remain available for an employer determined HRA run out period and can be used to pay claims incurred prior to the employee's date of death. After the run out period expires, any unused HRA funds revert back to the employer. If the dependents of the deceased employee elect to continue on the HRA as COBRA continuants, their HRA fund amount available remains unchanged. It will be the same as the available amount of the fund as of the employee's date of death.