12 Overview to COBRA Coverage

This chapter contains these topics:

12.1 Objectives

  • To comply with the regulations of the Consolidated Omnibus Budget Reconciliation Act (COBRA)

  • To enroll qualified beneficiaries in COBRA

  • To maintain COBRA election information

  • To track profile data on qualified beneficiaries

12.2 About COBRA Coverage

COBRA requires that most employers who sponsor group health plans offer employees and their dependents continuation of coverage at group rates that the employee would otherwise have forfeited due to a qualifying event. Federal and state agencies regulate COBRA coverage.

To comply with the requirements for COBRA coverage, complete the following tasks:

  • Process COBRA notification

  • Work with COBRA coverage

  • Work with COBRA profile data

This guide is not a replacement for the federal and state requirements. You should be familiar with the regulations and mandates provided through COBRA to implement and maintain your COBRA coverage benefits.

12.2.1 What Is a Qualifying Event?

Qualifying events are events that result in an employee losing group health coverage. Examples of qualifying events for an employee are:

  • Voluntary or involuntary termination of employment for any reason other than gross misconduct

  • Reduction in employment hours, such as changing from full-time to part-time status or taking a leave of absence

  • Eligibility to enroll in Medicare

Examples of qualifying events for a spouse include:

  • Death of spouse

  • Divorce or legal separation from a spouse

  • Eligibility of a spouse to enroll in Medicare

Examples of qualifying events for a dependent child include:

  • Death of parent

  • Dependent child ceases to be a dependent child under the employer's plan rules, for example, a child reaches age 18 and does not attend college or reaches age 21 and attends college

12.2.2 Who Are Qualified COBRA Beneficiaries?

A qualified beneficiary is any individual covered under the employer's group health plan on the day before a qualifying event occurs. Each qualified beneficiary who elects COBRA coverage receives the same core benefits that they were entitled to as an active employee. Qualified beneficiaries include:

  • Employee

  • Employee's spouse

  • Employee's dependent children

12.2.3 How Do You Comply with COBRA Coverage?

Employees and their dependents impacted by a qualifying event are entitled to COBRA coverage. You must notify employees that they are qualified beneficiaries and are eligible for COBRA coverage. Qualified beneficiaries are responsible for paying the premium for the plan and any administrative, or handling, fees that you incur. You administer claims and benefits for COBRA participants in the same way you do for employees enrolled in the same plans, including flexible spending accounts.

You can track the dates a qualified beneficiary is eligible for COBRA, elections, and payment dates. Initial notice letters can be sent and the date recorded. As with all Human Resources system programs, you can set up and maintain additional information, or profile data, for all qualified beneficiaries . For example, you can record medical history or plan remittance information.

After you enroll qualified beneficiaries, you can print reports to review information on the COBRA coverage. You can also print reports with the additional information obtained through the profile data that you choose to track.

The following terms are used throughout COBRA coverage:

Term Description
Benefit group Any group of employees enrolled in the same benefit plans and who receive the same benefits. Many companies establish a COBRA benefit group specifically for qualified beneficiaries who have elected to enroll in COBRA coverage.
Benefit plan Any benefit plan available with COBRA that is offered by the employer. These include, but are not limited to:
  • Medical and dental insurance

  • Flexible spending accounts

Dependent Any person, usually related to the employee, who is eligible for coverage in a benefit plan. A dependent is also a qualified beneficiary.
Qualified beneficiary A qualified beneficiary is anyone who is entitled to receive benefits from a COBRA plan. After a qualified beneficiary elects the COBRA coverage, the term COBRA participant is often used throughout the industry interchangeably with qualified beneficiary.
Qualifying event A qualifying event is any occurrence that causes an employee or qualified beneficiary to lose group medical coverage.