COBRA Data Exchange Technical Details

Learn Here How the COBRA Data Exchange Works

Click the following links

How to connect a client to the COBRA Data Exchange and Exclude Plans

Check the status of the connection

The “how” behind events being triggered on the COBRA files

Plans transmitted in the COBRA Data Exchange

Windows and Life Events that trigger COBRA on the Initial Rights (DOL) File

Events that trigger COBRA on the Qualifying Event File

Renewing, Adding or Changing Plans During Open Enrollment or Otherwise

Employee & Dependent information typically required by vendors to process a COBRA record

Troubleshooting error reports

How to end participation with a partner

How to connect a client to the COBRA Data Exchange and Exclude Plans

 You still need to select and coordinate the implementation with the vendor and sign any necessary agreements the vendor may need but after that........

Step 1: From the client’s home page, select COBRA under Data Feeds

Step 2: Select ‘add a service’, then from the drop down find the vendor you are connecting to, then click ‘add’.

Step 3: There will be a page displaying company information. Complete all fields that have missing data. This allows vendor to have some of the needed information when starting a new partner connection. 

Step 4: The next page will display brokers premier users and HR users for the company. Select a contact that you want for your primary subscription contact. 

Step 5: Verify the plans that will be sent for this client. Any of the plans NOT SELECTED will send on the file when an employee enrolls or loses coverage due to a qualifying event.

Click on "excluded plans". Select the box next to plan if the plan should not send on the file. Leave deselected if the plan should send on the file.

IMPORTANT NOTE: If you exclude plans you need to do so each plan year. Excluded plans DO NOT stay excluded upon renewing the plan.

If an employee has a retro term date entered, the system will make the prior plans the employee was enrolled the plans of record and send those plans on the COBRA file. If you had any plans excluded on prior year /  inactive plans, leave them excluded.

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Check the status of the connection

There are (4) status options that a Vendor can select:

1. New- The connection is in a New status. The Vendor will be reaching out for additional information they may need. No Data is being transmitted to the vendor during this time. 
2. Pending- The Vendor may move your group to a pending status if they are still gathering additional information from the Company. Usually, the Vendor will also test data to ensure the company's information is coming across on the file accurately. The broker is still responsible for continued data transmissions while it is a pending status. 
3. Active- It is assumed when the client is moved to Active that the vendor is processing data. In this status, if the vendor has scheduled files, Employee Navigator will generate files in the nightly job on the vendors schedule. However, this status cannot guarantee the vendor is actively processing those files. Confirm with the vendor if they are processing the files being sent.
4. Inactive- Vendor is no longer managing the data for the client. The Vendor should notify the Broker / Client before moving a company into Inactive status. Moving a company to Inactive status does not affect any service agreements made between the Vendor and Broker / Client.

Contact the vendor directly and ask for an update

As a side note, where did this “Identifier” come from? When the vendor accepts the client and moves them to pending they have to enter an identifier. Typically, this is the group ID or client name as it is in the vendors system. This is used to identify the client on the file. If this ever needs to be changed, the vendor will have to make the update.

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The “how” behind events being triggered on the COBRA files

Initial Rights File: The system will trigger a notice to the vendor on the Initial Rights File when an employee newly enrolls or newly enrolls a spouse in a COBRA Qualified plan when (1) they enroll in a window that triggers COBRA on the Initial Rights File and (2) enrolls in a COBRA Qualified plan. Refer to "Windows & Life Events that trigger COBRA on the Initial Rights file" and “Plans transmitted in the COBRA Data Exchange” for what windows / life events and plans will trigger a notice on the file. 

The notice will be sent to the vendor on their scheduled file following the employee’s coverage effective date. We do not send until the employees coverage has commenced. 

Examples:

• Employee is hired on May 5^th. They are eligible for coverage on July 1^st but employee has declined all COBRA Qualified Plans. The system WILL NOT trigger COBRA. Yes, the employee is a new hire but they did not enroll in coverage so a notice is not needed.
• Employee is hired on May 5^th. They are eligible for coverage on July 1^st. They enroll in medical, dental and vision on May 20^th. The system will trigger COBRA on the Initial Rights File on July 1^st. BUT the vendor may not receive the next file until July 5^th so the vendor would receive the notice on July 5^th.

Qualifying Event File: The system will trigger COBRA on the Qualified Event File when an employee OR dependent (1) has an event entered in the system that triggers COBRA and (2) is enrolled in a COBRA Qualified Plan and coverage is in effect.  NOT ALL events entered with the termination tool, update benefits or enrollment editor will trigger COBRA. Refer to “Events that trigger COBRA” and “Plans transmitted in the COBRA Data Exchange” for what events and plans will trigger a notice on the file.

The notice will be sent to the vendor on their scheduled file following entry of the qualifying event in the system.

Examples:

• Employee is terminating with the company on July 5^th. The employee is not enrolled in any COBRA Qualified Plans. HR uses the termination tool to terminate employee with a reason of voluntary termination. The system WILL NOT trigger COBRA. Yes, the term reason triggers COBRA but the employee was not enrolled in a COBRA Qualified Plan.
• Employee is terminating with the company on July 30^th. The employee has been enrolled since January in medical, dental and vision. On July 1^st HR uses the termination tool to terminate employee with a term date of July 30^th and term reason of voluntary termination. The system will trigger COBRA on the date the event is entered in the system. BUT the vendor may not receive the next file until July 6^th so the vendor will receive the notice on July 6^th.
• ABC Companies new plan year is approaching. On January 1^st their plans will renew. An employee re-enrolls in medical during open enrollment. The employee gives HR their notice to terminate employment in December but their last day will be January 11^th. HR uses the termination tool on December 20th and enters January 11th as the employees termination date. The system triggers COBRA BUT it triggers it on the current plan NOT on the plan the employee elected during open enrollment. This means the vendor will see on the file the plan that ends December 31^st with a coverage end date of December 31^st. Yes, technically the employee will be on the renewing plan upon their termination and that coverage will go through the end of January BUT the system does not trigger COBRA on plans in an open status. The system did show HR when they were terminating the employee that the open enrollment plan will be cancelled and the current plan will be the terminating plan of record. WHAT SHOULD BE DONE? Use the future termination field on the employee’s profile or HR will need to wait until after the open enrollment window is fully closed to enter the employee’s termination.

Important Note: The system logic for when an employees coverage effective date equals the termination date is to trigger a notice on the file. So if an employee did not work the day their coverage was effective then enter a termination date before coverage effective date.

• Example: Employees coverage effective date is 7/1/2018. They worked the full day on 7/1/2018 but at the end of the day they resigned. HR enters a termination date of 7/1/2018. The system will trigger a notice on the file. If the employee had not worked that day and COBRA should not be offered then HR should enter a termination date of 6/30/2018.

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Plans transmitted in the COBRA Data Exchange

There is nothing at the plan level that needs to be configured for plans to be sent on the COBRA Data Exchange Files. Employee Navigator triggers COBRA on certain plan types and if those plans types should not go over on the file, then they need to be excluded. Refer to Step 3 of “How to connect a client to the COBRA Data Exchange and Exclude Plans”.

Plans that trigger on the COBRA files:

• Medical
• Dental
• Vision
• Supplemental Health
• Telemedicine
• Prescription
• Health Reimbursement Account
• Health Savings Account
• Flexible Spending Account
• Limited Purpose Spending Account

IMPORTANT NOTE: We default to sending the Flexible Spending Account and Limited Purpose Spending Account on the file if the employee was enrolled and had a COBRA event. WE DO NOT know how much the employee has spent from their account which is needed to determine if they actually qualify for COBRA. Therefore, the COBRA Administrator should confirm with the FSA administrator or the client if the employee should actually be offered COBRA on these benefits. 

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Windows and Life Events that trigger COBRA on the Initial Rights (DOL) File 

The notice will be sent to the vendor on their scheduled file following the employee’s coverage effective date. We do not send until the employees coverage has commenced. 

Here are the windows or life events that trigger COBRA on the Initial Rights File.

• New Hire Window

• Newly Eligible Window

• Open Enrollment Window - system will trigger when employee newly enrolls (did not enroll in new hire), newly adds a benefit not previously enrolled or adds a spouse that was not previously enrolled. 

When using update benefits for life events these reasons will trigger COBRA:

For employee add:

• Employee Loss of Coverage
• Divorce or Legal Separation
• Death of Spouse
• Increase in Hours
• Return from Leave of Absence
• Spouse Loses Coverage at Their Employer
• Spouse Open Enrollment

For spouse add:

• Marriage
• Dependent Loss of Coverage 

 We do not trigger when coverage is imported or when the modify window is used.

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Events that trigger COBRA on the Qualifying Event File

The notice will be sent to the vendor on their scheduled file following entry of the qualifying event in the system.

When using the Termination Tool these reasons will trigger COBRA:

• 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 these reasons will trigger COBRA:

For the employee:

• Reduction in Hours (COBRA)
• Military Leave (COBRA)
• No Longer Eligible for Benefits (COBRA)

For dependents:

• Divorce or legal separation (COBRA)
• Dependent Leaves or Completes College
• Drop Coverage when Dependent Over Eligible Age

We do not encourage using the Enrollment Editor but if you do, these reasons will trigger COBRA when dropping coverage using Enrollment Editor:

• Divorce or legal separation (COBRA)
• Automated loss of dependent eligibility (36 months)
• Covered employee becoming entitled to medicare
• Death of employee
• Dependent change (add/delete/modify)
• Involuntary Termination (18 months)
• No longer eligible
• 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

The system will trigger COBRA when dependents are auto-dropped due to age and when importing employee terminations. 

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Renewing, Adding or Changing Plans During Open Enrollment or Otherwise

Let your vendor know when you have renewed plans, added plans or changed plans. We do not notify vendors of this so please communicate with them.  If they are not aware of plans renewed or added in EN, they will not know to go in an do needed mapping. Additionally they may need to add or change the plan in their system. The file output needs to match what they have in their system or their will be errors. 

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Employee & Dependent information typically required by vendors to process a COBRA record

Before you terminate an employee or dependent, you must enter the following information:  SSN, Date of birth, Gender, Current Address. 

Missing information could cause the vendor’s system to error the record which will result in the broker or client having to manually enter the event in the vendors system. Simply updating the missing information in Employee Navigator after the record errors will not cause the system to send the updated demographic information on the file. Demographic and Profile changes after a qualifying event has been sent to the vendor  DOES NOT resend on the COBRA files.

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Troubleshooting error reports

Employee Navigator does not have visibility into vendors systems nor are we familiar with the vendors error reports. Employee Navigator does not get a copy of the error reports from vendors. If the client receives an error report we ask you to first contact your vendor representative to troubleshoot. We are happy to research issues but please contact the vendor first to try and resolve.

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How to end participation with a Partner

There are 2 ways in which a data feed connection can be ended:

1. By the Partner: Notify the Partner to let them know your Company needs to be deactivated. At this point, the Partner can move the Company to an Inactive status immediately. There is no way to enter in a "future" date to end the participation. Please Note: Once in an Inactive Status, it will be the Partners responsibility to Re-connect your company again. 
2. By the Broker: For each company, select end participation for Partner to ensure the connection to Data Exchange is severed by clicking on the connected exchange> End Participation. This will end participation immediately. 

If a Company has been Terminated under your agency, please be sure to sever the Data Exchange connection prior to terminating the group

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