COBRA and Varying Dependent Eligibility Rules

Posted by BAS - 21 June, 2012


The Affordable Care Act requires group health plans that cover children of employees to provide that coverage up until age 26. However, the Age-26 requirement may not apply to each of an employer's group health plans. Benefits that are "excepted" from HIPAA, such as stand-alone dental and vision plans, do not have to extend coverage to age 26 for children.

Plan Sponsors need to be able to manage COBRA rights for children who age-out of ancillary group health benefits (such as dental and/or vision coverage), but remain eligible for other coverage, such as medical.

For example, ABC Company sponsors a medical plan, as well as separate dental and vision plans. Under the dental and vision plans, children can be covered up to age 22. Under the medical plan, children may be covered to age 26. Jane Employee is enrolled in family coverage under the medical, dental and vision plans. Jane has a daughter, Elaine, who turned 22 this month. Assuming ABC Company plans are subject to COBRA, Elaine must remain covered as a dependent under Jane’s active medical coverage, but should be offered COBRA for the dental and vision plans.

BAS supports this unique eligibility issue. The process is simple. While launching a Dependent COBRA Qualifying Event notice, under Step 3, select “COBRA event” and check the box to indicate the dependent should remain covered in the medical plan as a dependent of the employee (see example below).

Continue to follow the prompts to complete the dependent’s Qualifying Event Notice. If you have any questions along the way, contact your BAS Account Manager at 877.945.5513.

Topics: MyEnroll360 Feature

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