The Event Date is a Key Factor
The system will only trigger COBRA if the employee was enrolled in a plan at the time of the event. The employee needs to be enrolled in the plan that would have been in effect at the time of the employees termination.
Example: Broker obtains a new client. They want to have COBRA trigger for an employee that had coverage prior to obtaining the group. They enroll the employee in the plans they built that have a plan start date of 1/1/2019. Then they term the employee with a term date of 10/15/2018. The system will not trigger COBRA because the employee was enrolled in 2018 plans at time of termination, not 2019 plans.
Backdating Employee Termination Date
When an employee is retroactively terminated and the termination date coincides with an enrolled plan that had previously ended, the system will reinstate the prior plans making them current and then trigger COBRA.
Example: Company has an active enrollment for 1/1/2019 plans. Employee is enrolled in 2018 plans and has renewed his benefits for 1/1/2019. Open enrollment closes which makes the 2019 plans the current plans. On 1/2/2019 the employee is terminated with a termination date of 12/23/2018. Even though the 2018 plans have ended, the system will reactivate the employees 2018 plans and trigger COBRA on those plans. Since the employee terminated before the 2019 plans started, we will trigger on the 2018 plans.
Backdating Life Events and Enrollment Editor Drops
When an employee's coverage is retroactively dropped using life events or enrollment editor and the drop date coincides with an enrolled plan that had previously ended, the system WILL NOT reinstate the prior plans and trigger COBRA.
We currently do not support backdating life events and enrollment editor drops when it comes to COBRA triggers.
Entering a Future Event
If you are entering a future termination and the plan the employee will be enrolled in when they term is not in effect, it is best to use the future termination tool. If you do not use the future termination tool, the system will trigger COBRA on the current plans vs. future plans.
Example: Employee is enrolled in 2018 plans. The group is going through open enrollment and the employee enrolled in 2019 plans. The employee is going to terminate employment on 1/15/2019. HR goes into system on 12/22/2018 and enters the termination date of 1/15/2019. Since they did not use the future termination date tool, the system will trigger COBRA but on the 2018 plans and the coverage end date will not be correct.
BEST PRACTICE: Schedule the termination using "future termination date". This can be found on employees profile > employment > show additional info > use "Future termination date"