Continuation of Benefits

Continuation of Benefits - COBRA

Purpose: To comply with federal law (Consolidated Omnibus Budget Reconciliation Act of 1985, P.L. 99 272, and later amendments, otherwise known as COBRA).

Policy Statement: Covered employees and their dependents who lose insurance coverage for any of the following reasons are eligible to continue medical and dental insurance through COBRA: termination, reduction in hours, divorce or legal separation, death of the employee, eligibility for Medicare, or loss of dependent child status under the plan. All administrative rules and processes, such as open enrollment periods, as well as changes in plan benefits and premiums, apply to those on continuation coverage.

Procedures:

1. The Office of Human Resources is responsible for providing notification of COBRA eligibility and enrollment materials to the employee and dependents within 14 days of notification of termination, reduction in hours, death of the employee, or Medicare entitlement of the covered employee. In the event of divorce or legal separation, or the loss of dependent child status under the plan, a covered employee or dependent must notify the Office of Human Resources within 60 days to maintain the right to continue coverage. The Office of Human Resources will then provide enrollment materials to the employee or covered dependent within 14 days of that notification.

2. The covered employee or dependent has 60 days to elect continuation of coverage from either the date coverage would ordinarily have ended under the plan by reason of a qualifying event or the date of notification, whichever is later. Election of continuation coverage is established by completing and returning enrollment materials to the Office of Human Resources or the Plan Administrator, as applicable.

3. COBRA premiums will be billed by the applicable provider or Plan Administrator. The first premium is due within 45 days of the date of election. Subsequent premiums must be received within the terms set by the provider or Plan Administrator. Failure to make timely payments will result in termination of coverage without notice.

4. Continuation coverage under COBRA will end for any of the following reasons: the College discontinues its employee health plan; the premium payment is not made on a timely basis; the person who elected continuation coverage becomes covered under any other group plan or Medicare.

5. Continuation coverage will end after 18 months if the qualifying event was termination or reduction in hours, unless the qualified beneficiary is disabled at the time of termination or reduction in hours, in which case coverage may extend to a total of 29 months. Continuation coverage will otherwise end after 36 months.

6. The Office of Human Resources will notify continuation coverage enrollees of the annual open enrollment period and will provide them with opportunities to make changes in benefit elections.

Approved by the Executive Officers, June 24, 1992.
Revised November 11, 2004.
Revised June 4, 2008.