Understanding Qualifying Event or Subsequent Qualifying Event Entry

Before individuals become eligible for COBRA coverage, a qualifying event must occur. A qualifying event is any event that results in the loss of group health coverage for employees, their spouses, or their dependents, and that qualifies under COBRA legislation for continuation of coverage. As part of the COBRA notification process, you must enter COBRA qualifying events for qualified participants.

The key to COBRA administration is the ability to track important events. For example, you are required to record:

  • When the benefits administrator is notified of the qualifying event.

  • When notification letters are sent.

  • When COBRA coverage is elected.

This information is maintained when you enter qualifying events.

When you print the COBRA notification letter, you can also print the election form for COBRA coverage so that you can mail both forms together.

You can also enter a subsequent qualifying event for a participant. For example, an employee initially qualifies for COBRA coverage due to a reduction in hours. Currently, the maximum allowable coverage period for this qualifying event is 18 months. During that 18-month period the employee is terminated. This second qualifying event allows for a 36-month coverage period. When the second qualifying event has a longer coverage period than the initial qualifying event, you write a subsequent qualifying event record for the employee.

You can add subsequent qualifying events manually in the COBRA Qualifying Events program (P089102). The system can also create subsequent qualifying event information automatically when you change employee information that creates a subsequent qualifying event according to the rules that you specify in the rules engine.