COBRA Process Decision Tree

COBRA QUALIFYING EVENT OCCURS Yes Plan administrator receives notice of qualifying event from employer, covered employee, or qualified beneficiary For example, employee terminates employment and loses coverage Has the qualified beneficiary timely elected COBRA? If applicable, plan administrator must provide notice of unavailability of continuation coverage within 14 days of notice of qualifying event Plan administrator notifies qualified beneficiary of COBRA rights For termination, employer must notify plan administrator of qualifying event within 30 days Plan administrator must give election notice within 14 days after being notified of qualifying event Has the qualified beneficiary made timely initial premium payment? No COBRA coverage provided No No COBRA coverage must be provided up to maximum coverage period Qualified beneficiary must elect COBRA within 60 days after election notice, or, if later, loss of plan coverage Qualified beneficiary must make initial premium payment within 45 days after COBRA election Termination of employment: 18 months. Employees covered dependents loss of coverage: 36 months If employee becomes entitled to Medicare during COBRA, COBRA coverage will end i.e.: if employee elects COBRA for employee and spouse and employee dies within 18-month period, spouse can continue COBRA for up to 36 months Plan administrator must give notice of termination of COBRA coverage as soon as practicable after decision to terminate Maximum coverage period varies depending on type of qualifying event Events occur that may extend COBRA coverage beyond original maximum coverage period. If employee becomes disabled within the first 60 days of COBRA and is determined to be entitled so SS disability. COBRA coverage may by continued for up to 29 months from their initial qualifying event events occur that permit early termination of COBRA coverage COBRA ACTION ITEMS & DEADLINES