Beginning 10/1/10, HRA plans were required to report on a quarterly basis all covered HRA participants and dependents that meet specific criteria.  If Employers self administer their HRA, they are required to abide by this reporting as we

The purpose of reporting is to enable CMS to correctly pay for health insurance benefits of Medicare beneficiaries by determining primary vs. secondary payer responsibility. The employee/dependent data helps to assure that claims will be paid by the appropriate organization at first billing.
 
 
COBRA participants may be terminated from COBRA for many reasons; non-payment of premiums, voluntary termination, reaching the end of their maximum time frame under COBRA and when a qualified beneficiary becomes "Entitled to Medicare" are the most common reasons for terminating someone from COBRA.