Identifying COBRA Eligibility

Perform the following steps to specify that an employee or qualified beneficiary has become eligible for COBRA coverage:

Entering Personnel Actions to Trigger COBRA for Employees

Personnel actions that can trigger COBRA eligibility include: death of an employee, entitlement to Medicare benefits, termination of an employee, or reduction in hours worked that affects health coverage eligibility. These personnel action transactions are entered into the system via the Employee Status Maintenance (ESMT) page or the Department Specific Data (DEPTD) page of the Employee Profile Management (EPM) activity folder.

When entering a personnel action that triggers COBRA eligibility, the Personnel Action Code on the Employee Status Maintenance (ESMT) page or the Department Action Code on the Department Specific Data (DEPTD) page, must have the Trigger COBRA Review flag set to Yes on Personnel Action (PACT). Updating the personnel action generates a COBRA trigger, which is then processed by the COBRA Interface Table Updates (HH01000D) and creates a COBRA Attribute Maintenance (CAMT) entry for tracking purposes

Entering Personnel Actions to Trigger COBRA for Dependents

A dependent’s eligibility for COBRA is triggered by the same personnel action update as the employee if the qualifying events are related to a COBRA flagged personnel action. If, however, the qualifying events are not related to a personnel action, then the dependents’ COBRA eligibility must be triggered individually.

Qualifying events that are not related to personnel actions include incidents such as divorce that marks the end of COBRA eligibility. These types of qualifying events are entered into the system via the Dependent Profile (DPND) page of the Benefits Administration (BA) activity folder.

See Entering Personnel Actions to Trigger COBRA for Dependents for more information.

Identifying Dependents Approaching Coverage Limit

The last type of dependent action that triggers COBRA coverage is the loss of coverage because the dependent no longer fits the definition of a dependent under the coverage plan. For example, the dependent is 18 years old and is not a full-time student.

There is no user-entered action required for this to occur. The Dependents Losing Coverage (HB07000M) process is executed to perform a periodic sweep of the database to identify individuals affected by this change in status. Site Specific Parameters (SPAR) entries are used in conjunction with the dependent’s birth date, which is entered on the Dependent Profile (DPND) page of the Benefits Administration (BA) activity folder. This process also checks the full-time student status and any excluded disability codes to see if the dependent is eligible for extension of coverage. An output file is produced and uploaded to the COBRA Qualified Transactions (CQTR) table to trigger COBRA processing for affected dependents. Information regarding these dependents appears in the Dependents Losing Coverage Report (HBA7000), which is also produced when this process is run. For sites utilizing the Next Generation Payroll service, the Dependents Losing Coverage Report process also gives users the option to expire the dependent’s coverage on their birthday or at the end of the month by generating a Dependent Benefits (DPBN) transaction.

Processing COBRA Triggers

When a COBRA trigger is created, it is written to the COBRA Qualified Transaction table. The COBRA Interface Table Updates (HH01000D) evaluates the potential COBRA qualifying events that have been logged into the COBRA Qualified Transaction table in order to determine who is eligible to receive COBRA benefits.

This process evaluates whether the employee was enrolled into a COBRA-eligible benefits program on the date that the qualifying event and determines whether any dependents of the employee were covered by this program as of the same date. This process then creates COBRA Status Maintenance (CSMT) and COBRA Attribute Maintenance (CAMT) transactions for each qualified individual using existing data from the COBRA Qualified Transaction table and other employee benefit tables. It produces a COBRA Roster (HHA1000) activity report of all individuals that are potentially eligible for COBRA. Your organization’s COBRA administrator can then examine each case to determine whether the candidate is actually qualified to receive COBRA benefits.

Complete the Header information
Select Validate to make certain that your entries are correct.
Select Submit to record new beneficiary data in the system.
Select Beneficiary Designation Details from the Secondary Navigation Panel.
Click Insert New Line to create a new line. Result: A new line appears in the grid and the fields on the lower portion of the page become enabled.
In the Dependent ID field, enter the identification number associated with the dependent that you are enrolling in the benefit. The Dependent's name is displayed in the Name of Beneficiary field. If the Beneficiary is a Trust, enter only the Trust, Date of Trust, and Trustee fields.
Other dependent information is displayed from the Dependent table.
Enter the Beneficiary Type.
Select Validate.
Select Save.
To designate more beneficiaries, repeat steps 5 through 10.
Select Close to exit the Beneficiary Designation (BDES) page and return to the Benefits Administration (BA) activity folder.