May 16, 2012
Health Insurance - COBRA Continuation
- When does health insurance coverage end for an eligible
child, the end of the birthday month or the end of the birthday
Typically the end of the month in the child turns 26. For
more information on eligible dependents, see the It's Your Choice
- When an 'event' (such as termination) occurs requiring
that the employer provide a covered employee or their dependent(s)
with a Continuation-Conversion Notice (ET-2311) so as to comply
with COBRA law, does the employer need to submit a copy of the
ET-2311 to ETF to verify that the employee or dependent was given
notice of their right to continue group health insurance coverage?
The only time the employer must send a copy of the COBRA application
to ETF is when the 'event' making the person eligible for COBRA
is divorce. In these cases, the employer should attach the COBRA
notice to the subscriber's Health Insurance Application/Change
Form (ET-2301) (switching from family to single coverage if
no other dependents) or if maintaining family coverage but deleting
the spouse. ETF uses the advance COBRA form in divorce events
to set the effective date and duration of the ex-spouse's COBRA
rights. In all other cases, the employer is only responsible
for providing the ET-2311 COBRA application to their employee
or their dependent(s).
- Does the employer need to provide their employee with
a Group Health Insurance Application (ET-2301) along with the
Continuation - Conversion Notice (ET-2311)?
That depends on the circumstances. An employee going on COBRA
does not need to receive a Group Health Insurance Application
with the COBRA application unless the employee is changing from
family to single coverage (for example, their only dependent
no longer meets the definition of dependent) or if the employee
is changing health plans due to a move from the service area.
On the other hand, any dependents who receive a Continuation
- Conversion Notice must also receive a Group Health Insurance
- What steps need to be taken when a covered employee
is terminating but isn't eligible for an annuity?
The employer must notify them of their COBRA rights and provide
them with a Continuation-Conversion Notice (ET-2311) within
- When there's a divorce the employer must notify the
spouse (and any dependents losing coverage) of their COBRA rights.
Does the employer need to send a separate Continuation-Conversion
Notice (ET-2311) to the spouse and each step-child?
Only in the event the dependents losing coverage live at different
addresses, otherwise one COBRA form with the ex-spouse's name
on the form is sufficient notification.
- Is it the employee's responsibility to notify the employer
of a divorce? Sometimes the employer may know an employee is separated
from their spouse but don't know if or when the divorce will be
Yes, it is the employee's responsibility to notify their employer
of a divorce. The ex-spouse must then be offered COBRA. The
employee would need to file a Health Insurance Application/Change
Form (ET-2301) either to delete the spouse as a dependent, if
other dependents remain, or to switch from family to single
coverage if there are no other dependents.
- How does an employer locate all the dependents so that
they can all be notified of their COBRA rights and sent a Continuation-Conversion
Typically only the spouse is sent the COBRA application. If
the employee doesn't notify you of the dependents whereabouts
your only option is to send the COBRA application to the terminated
employee, who is responsible for notifying the dependent of
the COBRA option.
- When an employee with dependents is terminating employment
and doesn't want COBRA continuation, can COBRA be elected by the