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BN - FAQ COBRA Continuation Notice Process
The COBRA/Continuation Notice process (Process) has been centralized and is the responsibility of the UWSA Service Center (UWSC). The specific language in the Notice is determined by Job Data Action/Reason Codes.
What generates a COBRA Notice?
COBRA notices will be generated for certain Job Data changes entered into HRS, or life events for removal of dependents causing a cancellation of benefits. COBRA Notices will include information for all Benefit Plans the employee and/or dependents are enrolled in. Events that will generate COBRA/Continuation Notices include:1. Termination of employment
2. Movement between Benefit Programs resulting in a loss of benefits
3. Involuntary dependent removal
When are COBRA Notices printed?
Notices are printed, dated and mailed the day following when the change is made in HRS. If the Job Data row or enrollment change is entered on Friday, the notice will be printed, dated and mailed on the following Monday. Please allow an extra day for holidays. The notices are available in Cypress the day they are generated and will be available for 3 months before being archived. If you need an archived COBRA Notice, please contact your Affinity Group.
Where can I see an employee’s COBRA Notice?
COBRA Notices can be accessed in Cypress under Prod > UWSC – HRS > COBRA folder.
How does Benefit Administrator data entry drive COBRA?
COBRA Notices are created based on an “Election Date” and a “Deduction Begin Date” less than current System Date (Election Date) on the 'Enroll in Benefits' screens. ADM and MSC Events should be added to the BAS Activity Table (See KB 16921), changes made and the Event Finalized promptly to ensure COBRA Notices are generated, printed, and mailed on a timely basis (See KB 58169 for instructions). Future dated Events should not be finalized more than 90 days in advance to avoid having the employee missed in the process due to ‘Election Date’ being outside of the date criteria used by the process to generate the notices.
What are the best practices for ADM entry and Job Data Entry?
It is critical that Institutions use the correct Enrollment Code and Enrollment Reason when entering enrollments using an ADM Event in On-Demand Event Maintenance to ensure COBRA Notices are generated.
Use one of the following Enrollment Code / Enrollment Reason combinations:1. Remove Dependent - DivorceEvents in Job Data that trigger the termination of insurance must also have the correct HR Actions to ensure insurance is terminated correctly. Below are the HR Job Actions that will trigger COBRA Notices:
2. Remove Dependent - Grandchild’s Parent Turns 181. Termination
2. Layoffs (use any ‘Layoff’ Job Data Action/Reasons or ‘Retirement in lieu of Layoff’)
3. Movement from benefit eligible Benefit Programs to an LMT Benefit Program
Who is the official record keeper of the COBRA Notices?
The UW Service Center is the official record keeper of COBRA Notices. Institutions should follow their record retention guidelines for maintaining employee courtesy copies.
Who is responsible for counseling the employee?
Institutions will continue their general employment exiting responsibilities such as benefit counseling, collecting any home addresses, and updating HRS, as well as reviewing the employee's information on age and number of years of WRS (local and state) service to determine if a Sick Leave Certification needs to be submitted to Employee Trust Funds.
If the employee is eligible for Sick Leave Credit and they are over the normal retirement age but has not indicated they are retiring, it is best practice to remind the employee to submit a Sick Leave Credit Escrow Application, ET-4305, to avoid losing their Sick Leave Credit. If the employee is under the normal retirement age and has 20 or more years of WRS (local and state) service, the employee’s Sick Leave is automatically preserved, and no Escrow application is required. The Institution is responsible for submitting the Sick Leave Certification upon termination of employment.
What is the difference between a COBRA Notice and COBRA forms?
The COBRA Notice is an automatically generated notice informing employees of his/her Loss of Coverage and his/her rights following Loss of Coverage. The actual COBRA/Continuation or conversion forms are not provided with the Notice. The employee or dependent will be directed to contact the UW Service Center for the forms. The date on the forms will be the date on the COBRA Notice (or Amended Notice). The UW Service Center will then create and mail the forms to the requester. The requester must meet the deadline for submitting the forms to the vendors.
What benefit plans are employees eligible to continue under COBRA?
Employees may continue State Group Health, Dental, Vision, and Medical Flexible Spending Accounts.
Can employee's continue life insurance or Income Continuation Insurance?
Life insurance and Income Continuation Insurance plans are not covered under the COBRA laws. Income Continuation Insurance plans end on the first of the month following an employee's termination date and cannot be converted. However, employees can choose to convert their group life insurance plans into individual life insurance plans. The UW will send the appropriate Conversion Notices with the COBRA Notices if applicable when an employee terminates.
What if the employee gets Divorced?
COBRA notices will be generated to the ex-spouse once the dependent is removed from the State Group Health, Dental,Vision, State Group Life, AD&D, or Individual and Family Life Insurance plans. Remember to also change the employee's marital status to divorced on their Benefits Personal Data screen, (See KB 17882 for instructions) as well as change the relationship of the dependent under Update Dependent/Beneficiary from spouse to ex-spouse. (See KB 18182 for instructions.) If the employee is enrolled in State Group Life (SGL) Spouse/Dependent and/or Individual and Family Life, an employee must submit an application to remove the coverage. If the coverage is not removed, then the process is not triggered to send Conversion Notices.
(Life insurance plans require receipt of form within 31 days of loss of coverage.)
What if the dependent has a different address than the employee?
If the employee provides the address of the dependent(s), the Institution must update the Dependent/Beneficiary screen Address tab prior to the COBRA Notice being generated. The COBRA Notice will then be sent to the dependent’s address. If the employee and the dependent have the same address, the COBRA Notice will be sent to the employee's address. (See BN - Add/Update Dependents for steps on updating dependent addresses.)
An employee didn’t receive his/her COBRA Notice. Now what?
1. Verify the employee's mailing address is correct in HRS.
2. Go to Cypress and print out a copy of the Notice and send it to the employee.
3. If it is discovered a COBRA Notice was not provided and there are still eligible months remaining in the COBRA/Continuation period, we are required to send the standard NOTICE at the time of discovery. The individual will be eligible for the remaining period. Contact your Affinity Group to open a ticket if needed.
How do I request an Amended COBRA Notice?
The UW is legally obligated to send out an Amended Notice for the following reasons:1. Incorrect Job Termination ReasonIf an Amended Notice is needed, contact your Affinity Group to create a ticket. An amended Notice will be created by the UWSC Benefits team. Please do NOT reprocess the Event using On Demand Event Maintenance.
2. Late entry into HRS for insurance changes after termination
3. Incorrect Termination Date
4. Divorce date changes
When will an Age 26 dependent receive a COBRA Notice?
1. The COBRA Process generates a '90-day letter' on the first of the month. It will be printed and mailed to the employee. No forms are generated with the letter.
2. The Process will also create a '30-day letter' on the first of the month, which will be printed and mailed to the employee. No forms are generated with the letter.a. The program will also generate a letter for dependents entered after the initial 90 day run for his/her birth month.
3. COBRA Notices to the Adult Child will be available in Cypress the first week of the month in which they turn age 26.
4. NOTE: In cases of disabled adult children, please refer to KB BN - Adult Child Disability Process.
Who are the Letters Addressed to?
- Letters are addressed to employees for Termination, Retirement, and/or Layoff.
- Letters are addressed to the employee for his/her dependent child(ren) losing coverage due to Age 26.
- Letters are addressed to employee for his/her dependent child(ren) losing coverage due to Grandchild’s Parent Turns Age 18
- Letters for divorce are addressed to the ex-spouse and any children who may be removed due to the Divorce. Only one letter is generated for both the ex-spouse and any child(ren).
Upon retirement, what correspondence would an employee with benefits receive from the UW Service Center?
A COBRA notice, offering continuation for all health plans they are enrolled in except State Group Health (SGH). Conversion information will be provided for all life insurance plans except State Group Life (SGL). The Department of Employee Trust Funds (ETF) will provide all information regarding State Group Health and State Group Life to the retiree.