COBRA Data Exchange Technical Details

How does COBRA work with Employee Navigator? EN supports COBRA in two ways. 

1. COBRA notifications - when an employee newly enrolls in a group plan or an employee or dependent(s) lose coverage due to a qualifying event, the employee or dependent(s) need to be issued a notice of COBRA rights. EN supports the notifications through our COBRA data exchange if you are connected to an integrated TPA. 

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 Carrier's ONLY if the client is connected to EN's 834 files or the Carrier Data Exchange if the Carrier excepts COBRA enrollments on the file.

The following articles are related to #1 - COBRA notifications. The COBRA data exchange works separate from our COBRA enrollment tool. For more information on our COBRA enrollment tool, refer to this article. COBRA Enrollment Reporting

 

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 on the COBRA Qualifying Event file

How COBRA Works with Retro and Future Events

Renewing, adding or changing plans during open enrollment or otherwise

Employee and 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’.

Note: You DO NOT have to use subscriber groups. It is best practice to select "All Employees"

 

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

After you have connected, you can view the status of the connection. Vendors control when the group is moved from new, to pending to active. There are (4) status options:

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.

 

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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. Why?

The general notice has to be sent out 90 days from commencement of coverage. Often employees may terminate prior to coverage commencement and they would not need a notice

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.  

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

The following plans are set to trigger COBRA. There is nothing you need to do within the plan itself to make it COBRA eligible. 

If your client has plans that 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”.

• Medical
• Dental
• Vision
• Supplemental Health
• Telemedicine
• Prescription
• EAP COBRA Qualified
• Health Reimbursement Account
• Flexible Spending Account
• Limited Purpose Spending Account

So what about EAP?

Certain requirements must be met for an EAP plan to qualify for COBRA. For this reason, EAP is the only plan that allows you configure the plan as COBRA qualified or non-COBRA qualified. 

The "EAP COBRA Qualified" plan was newly released on 5/12/2019. If you have the EAP plan that does not trigger COBRA and there are enrollments in the plan, you cannot turn on COBRA for that plan. If the client's EAP plan is COBRA qualified and you want to start triggering COBRA on the data exchange, you will need to build a new plan using the "EAP COBRA Qualified" plan.

Important Note on FSA:

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. Why?

The general notice has to be sent out 90 days from commencement of coverage. Often employees may terminate prior to coverage commencement and they would not need a notice 

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/child 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.  Why?

Typically import is used when building out a new client and most likely they are not going to want a general notice sent out to all existing employees. And for modify, that is meant to correct an enrollment and should not be used as a standard practice to enroll employees. We find it is used often to correct enrollments and we would not want those employees getting another notice. 

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Events that trigger COBRA on the Qualifying Event File

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

We have several Termination reasons and Life Event reasons that trigger COBRA. Refer to the list below of COBRA triggers.  

Note! 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 qualifying event. 

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:

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)

For dependents:

• 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 a spouse or child event)

• Automated loss of dependent eligibility (36 months)
• Divorce or Legal Separation (36 months)
• 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 

2. Imports

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 data 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. 

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How COBRA Works with Retro and Future Events

Backdating Employee Termination Date

When an employee is retroactively terminated and the termination date coincides with an enrolled plan that is in a prior status, 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 is in a prior status, 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, you NEED TO use the future termination tool or the system will not trigger COBRA or pending timing, may trigger on the current plans set to end which would not be correct.

Schedule the termination using "future termination date". This can be found on employees profile > employment > show additional info > use "Future termination date"

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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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