Health Insurance - COBRA Continuation

• When does health coverage end for a full-time student who turns 25, the end of the birthday month or the end of the birthday year?

  The end of the year in which the student turns 25.

• 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 Heatlh Insurance Application/Change Form (ET-2301) (switching from family to single coveage 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).

• If a dependent child's health coverage ends due to their marriage, can the dependent elect family coverage through COBRA or are they only eligible for single coverage?

  Family coverage through COBRA may be elected in cases where dependent status is lost due to the dependent's marriage.

• Does the employer need to provide their employee with a Group Heatlh 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 Heatlh 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 Heatlh Insurance Application.

• 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 5 days.

• 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 final.

  Yes, it is the employee's responsibility to notify their employer of a divorce. The ex-spouse msut 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 Notice (ET-2311)?

  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 dependent only?

  Yes.