How does COBRA work with Employee Navigator? EN supports COBRA in two ways.
IMPORTANT NOTICE: COBRA HAS A LOT OF NUANCES AS WELL AS OUR SOFTWARE. WE HIGHLY RECOMMEND ALL USERS READ THIS ENTIRE ARTICLE AND BECOME COBRA EXPERTS DUE TO THE SIGNIFICANT LIABILITIES ASSOCIATED WITH COBRA.
1. COBRA notifications - when an employee newly enrolls in a benefit that is subject to COBRA (e.g. medical, dental, vision) or an employee or dependent(s) have lost coverage due to a qualifying event, the employee or dependent(s) need to be issued a notice of COBRA rights. EN supports the automatic notifications through our COBRA EN-Exchange if you are connected to an integrated TPA. Our software, for the notification process, is designed to be used with integrated COBRA TPA's
2. COBRA enrollment reporting - after an employee or dependent(s) have lost coverage, the Carrier will terminate the coverage. If the employee or dependent(s) decide to elect coverage through COBRA, their coverage needs to be reinstated with the Carrier's. EN supports reporting the reinstatement's (COBRA enrollments) to Carriers ONLY if the client is connected to EN's 834 files or the Carrier EN-Exchange if the Carrier excepts COBRA enrollments on the file. It is your responsibility to verify if COBRA enrollments are included with your Carriers' enrollment exchange.
The articles in this section are related to #2 - COBRA enrollment reporting. The COBRA tool works separate from our EN-Exchange and you need to understand how each work. Please refer to our COBRA EN-Exchange articles to learn about #1 - COBRA notifications. COBRA EN-Exchange Articles
VERY IMPORTANT - PLEASE READ
COBRA enrollment reporting IS NOT part of the COBRA EN-Exchange (this is the qualifying event notification process mentioned above). COBRA eligible participants notify the COBRA TPA if they wish to continue their coverage and the TPA's do not tell Employee Navigator if a participant has elected to continue their enrollment. It is your responsibility to verify with the COBRA TPA who will be notifying carriers when an employees coverage needs to be reinstated.
It is not intended for Employee Navigator to be the system of record for your participants on COBRA. The COBRA TPA is the source to use for reports and auditing COBRA.
Using the COBRA management tool is something you need to manage and is a manual process.
Enrollments entered on the COBRA tool will NOT trigger a notice of ANY SORT on the EN-Exchange. While actions taken in the system, such as terminating an employee or dropping coverage due to divorce, should trigger a Qualifying Event on the EN-Exchange and a COBRA Qualifying Enrollment Event on the COBRA Enrollment Tool, the EN-Exchange and the COBRA enrollment tool operate completely separate of each other.
COBRA Enrollment Reporting
When an employee or dependent has a COBRA Qualifying Event entered in the system, the system will trigger a COBRA Qualifying Enrollment Event which will allow you to elect COBRA for the employee or dependent. (Read more on this below: Actions that will trigger a COBRA Qualifying Enrollment Event on Manage COBRA so you can enroll in applicable benefits)
There are two main purposes for using the COBRA tool and enrolling an employee or dependents:
- Support COBRA enrollments sending on an 834 EDI file or carrier file if using the Carrier EN-Exchange AND Carriers accept those enrollments on the file.
- It will include the COBRA enrollment, if applicable, in ACA reporting.
Q: What if the employee was not in the EN system when they had their actual COBRA event? Example would be a new client we just put on the system and there were employees / dependents already on COBRA?
A: Skip the steps below and follow the steps in this article "adding a manual COBRA enrollment"
Enrolling an employee or dependent in COBRA
1. Go to the Employee Management Page (Employee's Home Profile Page)
2. Select "Manage COBRA"
3. Select "Elect" on the applicable COBRA Qualifying Enrollment Event
4. This will take you to COBRA Enrollment Editor
5. Select the actions menu
6. Select "elect" and enter a paid through date (see note below on paid through date)
The system supports the enrollment of just a spouse or child. You do not have to elect COBRA for the employee to enroll dependents. If you enroll just a spouse or child, the system will report on the 834 and carrier feeds the needed information for the dependents.
You cannot import COBRA enrollments.
To add a new dependent, such as a spouse or newborn, on an existing employee COBRA enrollment:
1. Go to the employees home page
2. Go to "Profile" and add the new dependent under "dependents"
3. Go back to the employees home page
4. Select "Manage COBRA"
5. Select "Edit" on the applicable COBRA Qualifying Enrollment Event
6. This will take you to COBRA Enrollment Editor
5. Select the actions menu next to the dependent
6. Select "elect" and enter a paid through date
Note! on Paid Through Date:
The system will not allow a dependent to have a paid through date greater than the employee. If the employee's COBRA coverage has ended and you need to extend the paid through date for a dependent, first end the employee's coverage. That will then allow you to enter a paid through date that is greater than the employee.
Staying on top of COBRA for file feeds
If you are using 834 EDI files or carrier EN-Exchange and are including COBRA enrollments, it is important that you maintain COBRA enrollments. Upon the plan renewing, you will want to update the employee's plan. Refer to the following article: Managing COBRA During Open Enrollment.
You will also want to immediately end coverage once the employee is no longer on COBRA. Usually this will come in the form of a notification from your COBRA TPA that the employee has not paid their premium.
Here is another article that has information on how to update dates / plans so data sends on files as needed: Editing COBRA plan, eligible start, eligible end and coverage level.
Actions that will trigger a COBRA Qualifying Enrollment Event on Manage COBRA so you can enroll in applicable benefits
We have several Termination reasons and Life Event reasons that trigger an enrollment event on Manage COBRA. Refer to the list below of COBRA triggers.
Some reasons will add the employee and any enrolled dependents while other reasons will only add the child or spouse (such as a divorce or child that aged off the plan).
When using the Termination Tool:
- Voluntary Termination (18 months)
- Involuntary Termination (18 months)
- Death of Employee
- Reduction in Force (18 months)
- Retirement (18 months)
When using update benefits for life events:
Note! Life events do not allow you to go back more than 30 days. If that is the case then use enrollment editor.
For the employee:
- Reduction in Hours (COBRA)
- Military Leave (COBRA)
- No Longer Eligible for Benefits (COBRA)
- Divorce or legal separation (COBRA)
- Dependent Leaves or Completes College
- Drop Coverage when Dependent Over Eligible Age
When using Enrollment Editor these reasons will trigger COBRA:
(remember to toggle to the correct dependent if it is the spouse or child event)
- Automated loss of dependent eligibility (36 months)
- Divorce or Legal Separation (COBRA)
- Covered employee becoming entitled to Medicare
- Death of employee
- Dependent change (add/delete/modify)
- Involuntary Termination (18 months)
- Other (COBRA)
- Other termination
- Reduction in force (18 months)
- Retirement (18 months)
- Voluntary termination (18 months)
- Loss of dependent child status (36 months)
- Military leave
- No longer eligible for benefits (COBRA)
- Reduction in hours (18 months)
- Drop coverage when dependent over eligible age
Other events that will trigger COBRA:
1. System dropped dependents
- The system will trigger COBRA when dependents are auto-dropped due to ceasing to be eligible for the plan
The system will trigger COBRA after importing employee terminations if you use a reason that triggers COBRA. The following reasons available when importing that trigger COBRA are:
- Involuntary Termination (18 Months)
- Death of Employee
- Voluntary Termination (18 Months)
- Retirement (18 Months)
- Reduction in Force (18 Months)
Note! If you do not enter a reason the system enters a reason of Voluntary Termination (18 Months) which WILL trigger COBRA so entering a reason is important if you are using our COBRA EN-Exchange.
3. Class changes
- If you have plan eligibility based on class structure (classes, departments, divisions, business units, or dynamic class) and you change the employee to a class structure that would change their eligibility for current enrolled plan, the system will offer a choice for you to drop the enrollment or skip it. If you drop it, the system will trigger COBRA. It is advised to not select drop if the class structure change does not warrant the offer of COBRA. If this is the case, select skip and then use enrollment editor to end the benefit(s) using a reason that does NOT trigger COBRA. EN has it on our road map to change how this works by adding an option if drop is selected to then ask if it is COBRA eligible. Please follow our product news and updates and watch for this enhancement.
COBRA eligible plans
The following plans are set to trigger COBRA. There is nothing you need to do within the plan itself to make it COBRA eligible.
- Supplemental Medical
HRA, EAP, & FSA are not COBRA enrollable benefits at this time. Why? It is not common these benefits are 1. elected under COBRA, and 2. report out on 834 files. Most likely FSA and HRA are being administered by the same TPA as your COBRA TPA so it seems those teams should communicate with each other. It is on our long term strategy to add these.
Note! The system will trigger a notice on the COBRA EN-Exchange for HRA, FSA, and EAP. They are just not enrollable benefits on the COBRA tool.
- Qualifying Event Date: the date entered for the event. i.e. employee's termination date or date of employee's divorce.
- Coverage Loss Date: the date the employee / dependent(s) coverage ends.
- COBRA Start Date: the first day following the coverage loss date.
Example: The plan termination rules indicate coverage goes through end of month. An employee is termed in the system with a termination date of 6/3/2019.
The employees qualifying event date is 6/3/2019, their coverage loss date is 6/30/2019 and their COBRA start date is 7/1/2019.
The reports listed below pull employees that are on COBRA:
- Carrier Billing Reports
- COBRA summary
- COBRA detail