Q.- We conducted a dependent eligibility audit and found about 30 people who were enrolled in our health plan as a dependent but didn’t meet the plan’s eligibility requirements. Some were just friends of employees, others were children in their 30s. We are removing the individuals from health coverage, but do we have to offer them COBRA?
A.- Not necessarily, but pay attention to the reason the person is not eligible for coverage as a dependent on your plan. Simply losing active health coverage for failing to meet the plan’s eligibility requirements is not a COBRA qualifying event. However, losing active health coverage for aging out of the plan (and no longer meeting plan eligibility) is a COBRA qualifying event for the child and losing active health coverage for divorce or legal separation (and no longer meeting plan eligibility) is a COBRA qualifying event for the ex-spouse. If you did not previously offer a COBRA election to an individual who was once an eligible dependent, you may have not followed the COBRA rules and a COBRA election could be appropriate now. Consult your legal counsel for specific guidance.
Benefit Allocation Systems (BAS) provides best-in-class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.
MyEnroll360 can Integrate with any insurance carrier for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and many others), and integrate with any payroll system for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and many others).
