Common COBRA Data Exchange Questions
Will each vendor be able to provide services in all states? Do they only administer COBRA or can they also administer mini-COBRA or State Continuation Coverage?
You will need to contact the vendor directly to have them define their scope of capabilities.
Employee Navigators COBRA logic is based on Federal COBRA. The system does not distinguish clients, in terms of COBRA, by group size or if a client is subject to COBRA laws or State Continuation Laws.
What are the fees for the COBRA administration?
All fees for COBRA administration are contracted directly through the vendor and Employee Navigator is not a part of that process. You should work with the vendor directly to determine those fees and who will be paying the fees for the service.
How do I confirm if the vendor is actively processing the Data Exchange files sent by Employee Navigator?
While the status of the connection can give some indication if the vendor is processing the files, it is advised to confirm directly with the vendor. Employee Navigator cannot confirm if the vendor is processing the files being sent.
Why did an employee receive a notice for a plan that the employer does not offer COBRA on?
Check to make sure the plan is excluded from the file. Refer to COBRA Data Exchange Technical Details "How to connect a client to the COBRA Data Exchange and Exclude Plans".
Does this service only cover COBRA Qualifying Events Notice or will it also handle Initial Rights Notice?
The COBRA Data Exchange has the functionality to handle COBRA Qualifying Events and Initial Rights Notice to the vendors. The vendors receive notification via the Qualifying Event XML File and Initial Rights XML File. The standard practice is that the vendor will receive both XML files but confirm with your vendor if they are taking / processing both files.
Will Employee Navigator maintain a record of the date the vendor mailed the notices to employees?
No. The vendor is the record holder of this information and it will not be transferred back to Employee Navigator.
If an employee elects COBRA will that feedback into Employee Navigator?
No. Employee Navigator does not receive data back from the vendor. You will need to discuss with the vendor who will be reporting back to carriers when an employee’s coverage needs to be reinstated due to a COBRA election.
If you use the Manage COBRA tool to elect coverage for prior employees which can then send, if included, on the EDI feeds to various carriers, it is still your responsibility to elect the coverage in Employee Navigator. The COBRA Data Feeds do not report back employees that elect coverage under COBRA.
How should we manage Grandfathered Employees or special situations such as subsidized COBRA in Severance?
Any special situations should be discussed directly with the vendor.
When do the events entered in Employee Navigator that trigger COBRA send on the files?
Initial Rights File: Notice will be sent on the employee’s effective date of coverage. We do not trigger prior to effective date because some employees may terminate employment prior to coverage starting.
Qualifying Event File: Notice will be sent at the time of entry in the system.
Note: The timing of the vendor receiving these will depend on the vendors file schedule.
How long does it take for the files to be processed and notices sent to employees?
We do not set requirements for how often Vendors must pick up data from the Data Exchange. Most vendors will set up their own Schedule of when they will receive the files. Please contact your vendor directly if you have further questions.
What happens if I update a prior employee’s profile or demographics. Will that send to vendor on COBRA files?
NO. Demographic and profile changes after an employee has experienced a qualifying event will not send on the COBRA files. You will need to work with the vendor directly to have profile and demographics such as address changes or SSN updated in their system.
Do you support bundled plans?
Why do I need to unbundle them for the COBRA? Let’s look at an example to explain why this needs to be done. Ex: You have a combined medical and dental plan and built a single plan in Employee Navigator. Based on COBRA regulations, you may need to allow an employee to elect COBRA for the dental plan only. If this is the case, we cannot split up a medical plan, you should build separate medical and dental plan and use our plan restriction tool to ties the medical and dental plan together. In summary, if you expect to have two qualifying events sent to the vendor, set up two plans
How can we see what Qualifying Events have been submitted and when they were submitted?
For phase 1 of this product release the visibility into this data is not available. You will want to check in with your vendor to ensure that notices are transmitted.
How is COBRA for FSA plans handled?
Employee Navigator can send notice on the files for FSA and Limited Purpose FSA. HOWEVER, the clients FSA vendor must determine the eligibility based on a positive account balance for the employee. Employee Navigator does not know the balance in an employee’s FSA / LPFSA account to determine eligibility.
Does Employee Navigator provide the COBRA rates to vendors?
While vendors can view some plan information for connected clients which may include the rates in Employee Navigator, it is your responsibility (or the clients) to provide the COBRA rates to the vendor.