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Table Of Contents
Table Of Contents - COBRA Procedures Manual & E-Alerts
An Overview Of COBRA
Background
Purpose
Administration
Cost To Employers
Penalties For Noncompliance With COBRA
Employers And Plans Covered By COBRA
Employers And Plans Subject To COBRA
Defining A Group Health Plan
Maintaining A Group Health Plan
The General COBRA Notice
The General COBRA Notice
Consequences Of Failure To Provide The General COBRA Notice
How To Send The General COBRA Notice
HIPAA Notice
Covered Employees And Qualified Beneficiaries
Who Is A Covered Employee
Who Is A Similarly-Situated Non-COBRA Beneficiary
Who May Be A QB
Who May Not Be A QB
A QB’s Rights Under COBRA
QBs Located Outside Of The Plan's Service Area
Repeal Of The Core Coverage Requirement
Qualified Events
Defining A Qualified Event
List Of Qualified Events
What May Be A QE
Expansion Of COBRA's Loss Of Coverage Definition
What May Not Be QE
Duration Of COBRA Coverage
Expanded Coverage For Additional QEs (Multiple QEs)
Special QE Issues: Gross Misconduct
Special QE Issues: Disability
Special QE Issues: Cessation Of Dependency Status
Special QE Issues: Divorce Or Legal Separation
Special QE Issues: Medicare And Initial QEs
Special QE Issues: Medicare And Multiple QEs
Determining The QE Date
Providing More Than The Required COBRA Coverage
COBRA Notice Rules: Reasonable Notice Procedures
QE Notices
QE Notices
What QE Notices Should Include
To Whom Should QE Notices Be Sent
When To Send A QE Notice
How To Send A QE Notice
Handling Coverage During The Election And Payment Period
Responses To Provider Inquiries Concerning QBs
COBRA Issues Under The Trade Act Of 2002
Introduction
Second Chance COBRA Election
Health Coverage Tax Credit
Administration And Documentation
Coordination Of Administrative Resources
Summary Plan Descriptions
Keep The Envelopes, Use The Postmarks
Timelines
The COBRA Timeline
Understanding And Managing The COBRA Timeline
Employer And QB Notification To The Plan Administrator
14-Day Notification Period
60-Day Election Period
45-Day Retroactive Premium Payment Period
30-Day Grace Period
Using The Correct Procedures
Strategies For Protecting Against Accidental Free COBRA Coverage
Finding Out About Other Coverage
Calculating COBRA Premiums
Determining COBRA Premiums For Insured Plans
Determining COBRA Premiums For Self-Funded Plans
Handling Rate Changes
COBRA’s 12-Month Determination Period
Determining Rates For Related QB’s Who Independently Elect COBRA
Rates For A QB’s Newly Added Spouse or Dependent
Billing And Collection Of COBRA Premiums
How To Bill Current QBs
Who To Bill For COBRA Coverage
Who Can Pay For COBRA Coverage
What Is Timely Payment: Premium Payment Deadline
What Is Timely Payment: Timely Payment
What Is Timely Payment: Partial Payment
What Is Timely Payment: Employer Subsidized / Alternative Coverage
Open Enrollments
Who Is Entitled To Open Enrollment Rights
Changes In Coverages During Open Enrollments
Effect Of Plan Terms On QBs' Open Enrollment Rights
Plan Changes And Their Effect On QBs
Open Enrollment Changes By Active Employees And Potential QEs
USERRA
Introduction
Protected Individuals
Health Care
Interaction With COBRA
Election Notice
Health Care Premiums
USERRA Does Not Extend Beyond 18 Months Of Continuation Coverage
Medicare
Medicare Basics
Entitlement vs. Eligibility
Medicare And Initial QEs
Medicare And Multiple QEs
Medicare As An Event Terminating COBRA Coverage
COBRA's Alternative Coverage Rules
Defining Alternative Coverage
Using Alternative Coverage To Offset COBRA
Consecutive Coverage Method
Concurrent Coverage Method
Choice Method
Making Your Alternative Coverage Method Work
Choosing The Correct Method
Terminating COBRA Coverage
An Overview Of The Rules Governing Terminating COBRA Coverage
Events Terminating COBRA Coverage
Natural Expiration Of COBRA Continuation Period
Termination Of COBRA Because Of Employer's Cessation Of Health Plan Sponsorship
Termination Of COBRA For Failure To Pay Premiums
Termination Of COBRA Because Of Other Group Health Plan Coverage Or Medicare Entitlement
Termination Of Extended Disability COBRA Coverage Because Of Cessation Of Disabled Status
Procedures For Terminating COBRA Coverage
Other Issues
State Laws Health Care Continuation Rules
COBRA And the Family And Medical Leave Act
Conversion Coverage Rules
Flexible Spending Accounts
Deductibles, Limits, Split Family Units
Penalties For Non-Compliance
Sample Forms, Notices, And Checklists
Documentation Form
General COBRA Notice
QE Notice - Termination/Reduction
QE Notice - Cessation Of Dependency
QE Notice - Death/Divorce - L.S./Medicare
HIPAA Request For Certificate Of Coverage
HIPAA Certificate Of Coverage
HIPAA Certificate Of Coverage By Categories
Termination Of COBRA Coverage Notice
Responsibilities Checklist
About The Manual
IRS Notice 98-12
About COBRA Continuation Coverage Rights
Notice Of Unavailability Of Coverage
Adminstrative Procedures
Suggested Procedure For Sending The General COBRA Notice
Suggested Procedure For Identifying QEs
Suggested Procedure For Managing Cessation Of Dependency Status Issues
Suggested Procedure For Sending QE Notices
Suggested Procedure For Handling Coverage During The Election And Payment Period
Suggested Procedure For Late and Partial Payments And Bounced Checks
Suggested Procedure For Open Enrollment Changes
Suggested Procedure For Determining Medicare Entitlement
Suggested Alternative Coverage Procedure: Concurrent Coverage Method
Suggested Alternative Coverage Procedure: Choice Method
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