If your coverage under the Certificated Employee Health Plan ends, you may be able to continue coverage under the Consolidated Omnibus Budget Reconciliation Act, a federal law referred to as COBRA. This law allows employees and eligible dependents whose health insurance would otherwise terminate to continue the same benefits for specific periods of time under certain conditions. Covered individuals may continue coverage if all of the following conditions are met:

  1. Coverage is lost due to one of the “qualifying events” outlined below

  2. Covered individuals are not insured under another group medical plan as an employee or dependent. (This restriction is waived if you or your dependent enrolls in another group medical plan that has a pre-existing conditions clause, and a condition exists that is not covered by the other plan. In this situation, you must provide the following to Employee Benefit Services: (1) a letter from the new employer or claims administrator explaining that plan’s pre-existing condition clause and how long it applies, and (2) a letter from your physician attesting to your pre-existing condition.

 

The COBRA administrator will send a COBRA notification packet to your home address after being notified of coverage termination. This will occur after all leave has been used and one of the qualifying events occurs. COBRA-eligible members have 60 days from receipt of the COBRA notification packet to return the application to the administrator. Coverage will be reinstated as of the termination date if premiums are returned with the application. Please make sure your correct home address is updated in ESS (or with Human Resources). If you do not receive your notification letter within 30 days after your insurance terminates, contact Employee Benefit Services.

 

You or one of your family members must notify Employee Benefit Services if a dependent wants to continue coverage under COBRA because of a divorce or because a dependent child is no longer eligible for coverage because of a loss of dependent status.

 

Reporting a COBRA event

In the event of divorce or loss of dependent status, you or your dependent has 60 days from the date of the qualifying event or the date the insurance will terminate due to the qualifying event (whichever is later) to notify Employee Benefit Services. Failure to notify Employee Benefit Services within 60 days of the loss of coverage will eliminate any rights to COBRA continuation. Employee Benefit Services will only accept written notification and will supply you with a COBRA Event Notice form to complete.

 

The COBRA administrator will then send your dependent the COBRA enrollment packet to your address. Rules for returning the enrollment form, including when premiums must be paid and other provisions, are outlined in the COBRA packet. Failure to report a dependent becoming ineligible to continue coverage within 60 days of the loss will result in the dependent not being offered the opportunity to continue coverage under COBRA, as their 60-day eligibility period will have lapsed.

 

There may also be a requirement for you to notify Employee Benefit Services in the event of a disability determination by the Social Security Administration. See additional information regarding disability extensions below.

COBRA continuation period

The maximum length of time coverage may continue under COBRA depends on which qualifying event causes your loss of coverage, as shown below.

 

Qualifying events

 

For employees

You may continue your single or family medical coverage for a maximum of 18 months if coverage is lost due to one of the following qualifying events:

  • Employment is terminated for any reason other than gross misconduct

  • Work hours are reduced below 30 hours

  • Changes in your job appointment make you ineligible for coverage (example: changing to a part-time position)

For dependents

Dependents may also continue their medical or dental coverage under COBRA for 18 months based on the events listed above for employees. Dependents may continue medical or dental coverage for an additional 18 months (for a maximum of 36 months) if coverage is lost due to one of the qualifying events listed below:

  • Your death

  • Your divorce from your spouse

  • You become entitled to Medicare prior to enrolling in COBRA (the 36-month period is retroactive to the date of Medicare entitlement)

  • Your dependent child is no longer eligible as a dependent (married, in the Armed Forces on a full-time basis, over age 26 unless meeting qualifications for incapacitation, etc.)

  • A child born to or placed for adoption with you during a period of COBRA continuation coverage is also eligible for continuation of coverage, provided coverage is requested within 60 days. 

 

COBRA premiums

COBRA premiums are equal to 102 percent of the total monthly premium, which includes both employee and employer contributions. Premiums are not prorated. When your COBRA coverage ends, you may be eligible to convert to a private, direct-pay plan with your health provider. 

 

If you or your dependents are on an 18-month COBRA extension and were disabled when you originally lost coverage or within 60 days of when your or your dependent’s coverage started, you and your dependents may continue coverage for an additional 11 months with an increase (150 percent of the total monthly premium) in payments after the 18th month. In order to qualify, an award letter from the Social Security Administration (SSA) must be sent by the COBRA participant to Employee Benefit Services within 60 days of your receiving SSA’s disability letter. You will be notified if the additional 11 months are approved.

When COBRA ends

Any COBRA coverage ends on the earliest of the following:

  • The required premium is not paid by the due date

  • You or your dependents become insured under another group health plan after the date you elect COBRA coverage under this plan. (Exception: Your COBRA coverage will not be terminated if, on the date you obtained the other coverage, the other group health plan contained a pre-existing condition clause that applies to or is not otherwise satisfied by you or your dependent under the provisions of HIPAA. Contact Employee Benefit Services if you believe this applies or if you have questions.)

  • You or your dependent becomes entitled to Medicare after the date you elect COBRA coverage under this plan

  • Coverage has been extended for up to 29 months due to a disability and there has been a final determination during the 11-month extension period that the individual is no longer disabled

  • On the last day of the appropriate 18-, 29- or 36-month period

COBRA

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EMPLOYEE BENEFIT SERVICES

615-259-8607

2601 Bransford Avenue

Nashville, TN 37204

benefits@mnps.org

615-214-8665 (fax)

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