Cobra Notifications

szemcumo

When EE becomes eligible for benefits I send out Initial Notification to ee and covered dependents separately. When ee terms I do paperwork in office with them. If they sign off not wanting continuation do I then need to inform dependents again of their rights or was this covered in Initial notice mailed? Your help is greatly appreaciated. (If yes do you have copy you could mail me for that reason?)
[email]szemblidge@versa-tags.com[/email]

mwild31

I could be wrong here, but I don't think you're covered. The time between the initial notification and the time of the ee's termination could be months or years, so they might forget or be fuzzy on the details. Also, and maybe this is not the best practice, but it's what I do, I don't let the ee make the determination at the term meeting for COBRA participation. Instead, in the term meeting I inform the ee that they are eligible for COBRA and that they will receive a packet in the mail describing the program in more detail, including costs and time frame to return the paperwork.

marc

Our practice is similar to Mwilds. They get some time to make the decision.

LindaS

Based on the above information, you are not fulfilling your COBRA obligations as I interpret the regs. to be. First of all you are only required to send the initial notice separately to the dependents if they live someplace other than with the employee. What I normally do is address the envelope to "Mr. John Doe and Dependents". Simply putting the notice in the SPD is not adequate.

Second, when the EE terms each dependant has an individual option of electing coverage. The EE cannot make the election for all dependents so that is where I think you may run into problems. In addition, the EE (or other participant) has 45 days to elect coverage and if they are signing off at the term. meeting, they may come back and say that they were pressured into signing off their COBRA rights.

Best case scenario is to send the election forms to the participant, and dependents, via certificate of mailing. That way you have the proof the information was sent timely.

irenesmsaclaims

All of the above responses are correct except that the qualified beneficiary has 60 days to elect, from the time the election notice is sent, and 45 days from the date of election to pay the first premium for COBRA. Each qualified beneficiary, including dependents should be listed on the election notice. It's OK to send to the same address (of record). Certified mail is recommended.