Processing Enrollments for Secondary Events

When a secondary event is processed, the system reviews the initial event to determine whether its event status is Closed to Processing (indicating that the participant has made an election or waived COBRA coverage). If the initial event is not closed, the secondary event's status becomes Qualified Pending. The secondary event needs to be reprocessed after the initial event is closed.

This can happen if dependents are covered under an employee's coverage instead of electing independent coverage.

For example, suppose that an employee and her dependents become qualified beneficiaries after she terminates her employment. She enrolls in family coverage for plan types 10 and 11—covering herself, her spouse, and her daughter—and waives plan type 14. As a result, the terminated employee's record is Closed to Processing. But the dependents' records remain Open for Processing because they have not independently elected or waived coverage.

To close an initial event and reprocess a secondary event:

1. A secondary event, such as a divorce or dependent marriage, occurs.

   The HR system processes the personnel action.

   The COBRA process evaluates the secondary event and returns a status of Qualified Pending.

2. Determine whether the initial event is still Open for Processing because the dependent records were not waived or enrolled.

3. Waive or elect options for the dependents and run the COBRA process to close the initial event.

4. Use the Update Event Status page to reprocess the secondary event by changing the reprocess status for the secondary event to Qualify Event.

   After you run the COBRA process again, the secondary event should be set to Qualified.

When secondary events occur, COBRA participants with individual coverage are processed differently from those with dependent coverage.

For participants with individual coverage, a secondary event extends coverage according to the defined secondary event rules. The system deletes the existing termination record, reinserts it into the coverage begin date, and sets an effective date equal to the extended COBRA coverage end date + 1. The COBRA enrollment status is set to Coverage Extended.

Participants with dependent coverage are switched to individual COBRA participants, with individual COBRA coverage as of the COBRA event date of the secondary event. The system automatically establishes the participant as a nonemployee in the system and enrolls the participant in employee-only coverage for all plan types that meet this condition. The employee-only coverage is within the same benefit plan under which the participant was covered as a dependent under COBRA. The coverage end date is calculated based on the predefined secondary event rules, and the COBRA enrollment status is set to Coverage Inserted.

A COBRA event can be an initial event for one plan type and a secondary event for another type. For example, suppose that an employee has Employee Plus Spouse coverage for plan types 10, 11, and 14. Then the employee transfers and both the employee and the spouse lose coverage under plan types 11 and 14; they are eligible for 18 months of COBRA coverage for these types, and they elect this coverage.

The employee divorces while the COBRA coverage is still active. The divorce event causes the employee's ex-spouse to lose coverage for plan type 10 (an initial event); the ex-spouse is qualified for 36 months of COBRA coverage under that plan. The divorce is also a secondary event for plan types 11 and 14; the ex-spouse is qualified to have coverage extended for those plans for up to 36 months from the original coverage begin date.

The two events—the initial event for plan type 10 and the secondary event for plan types 11 and 14—progress through the COBRA system independently in terms of notification letters and ongoing status indicators.