Human Resources

Eligible Reasons to Elect COBRA  

Employees have a right to choose COBRA benefits when coverage is lost due to:

• a reduction in work hours, or
• termination of employment (other than for gross misconduct), including retirement.

Coverage is extended only to those individuals covered at the time of termination and may only continue the level of coverage that was in effect on the day of termination, or a lower level of coverage.

Covered dependents also have a right, independent of the employee's right, to COBRA coverage. The covered dependent may elect COBRA even if the employee does not. A spouse or dependent child covered under an employee's Indiana University medical and/or dental plan has the right to elect COBRA continuation coverage if they lose coverage due to:

• the employee's death; the employee's termination (other than for gross misconduct), or reduction in work hours at IU; divorce or legal separation from the employee; the employee's entitlement to Medicare; or
• if a covered individual ceases to meet the definition of a dependent.

Required Notice

Indiana University must depend on notice from the employee when certain events occur that would qualify the employee or dependent for COBRA. Under COBRA regulations, the employee or family member is responsible for informing the University of such events, including: divorce, legal separation, or a child losing dependent status (e.g., due to marriage). Such notice must be within 30 days of the later of the following dates: date of the event, or date on which coverage would end under the plan because of the event. When Indiana University determines that an employee or dependent has experienced an event that qualifies the enrollee for continuation coverage, IU – through its COBRA administrator, HRPro - provides a written notice of COBRA rights and an application for the employee and dependents (the COBRA offer letter). The employee and/or dependents have 60 days from the date that coverage would end or the date of the COBRA offer letter, whichever comes later, to elect COBRA.

Length of Coverage

The length of COBRA coverage is between 18 and 36 months, depending on the circumstances: 

• 18 months when coverage is lost due to termination or reduction in hours;
• 29 months when coverage is lost and individual becomes disabled within 60 days of termination;
• 36 months when coverage is lost due to death, divorce, legal separation, or loss of dependent child status.
  

Extending COBRA Coverage

An 11-month extension of COBRA coverage may be available if an individual becomes disabled (for Social Security disability purposes) within 60 days after the time of the termination, and the COBRA administrator is notified of that determination within 60 days. The affected individual must also notify the COBRA administrator, HRPro, within 30 days of any final determination that the individual is no longer disabled. In no event will COBRA continuation coverage last beyond three years from the date of the event that originally made a qualified beneficiary eligible to elect coverage.

An 18-month extension of coverage will be available to spouses and dependent children who elect COBRA continuation coverage if a second qualifying event occurs during the first 18 months of continuation coverage. The maximum amount of continuation coverage available when a second qualifying event occurs is 36 months. Such second qualifying events may include the death of a covered employee or a dependent child's ceasing to be eligible for coverage as a dependent under the COBRA continuation plan. These events can be a second qualifying event only if they would have caused the qualified beneficiary to lose coverage under the active employee Plan if the first qualifying event had not occurred. You must notify Indiana University’s COBRA administrator, HRPro, within 60 days after a second qualifying event occurs if you want to extend your coverage.

Electing COBRA Coverage

Each qualified beneficiary has a separate right to elect COBRA continuation coverage. A parent may elect to continue coverage on behalf of any dependent children. The employee or employee's spouse can elect continuation coverage on behalf of all of the qualified beneficiaries. If you elect COBRA coverage and have a newborn child, or a child placed with you for adoption, then that child will be considered a dependent for COBRA purposes.

In considering whether to elect COBRA continuation coverage, you should take into account other group health plan coverage options for you and your family (such as a spouse’s plan) through what is called a “special enrollment period.” Because of the qualifying event listed above, you have the right to request special enrollment in another group health plan for which you are otherwise eligible within 30 days after your group health coverage ends. You may also consider other health plan coverage options through the Health Insurance Marketplace or Medicaid. Some of these options may cost less than COBRA continuation coverage. You can learn more about many of these options at www.healthcare.gov.

Reasons Why Coverage May End

If the employee does not elect COBRA within 60 days, coverage under the IU-sponsored health plan ends on the date they were no longer an active employee or otherwise eligible for the IU plan. If the employee or dependent elects COBRA, their COBRA coverage may also end when:

• COBRA premiums are not paid on time;
• the enrollee becomes covered under another group health plan which does not limit the coverage for an enrollee's preexisting condition;
• the enrollee becomes entitled to Medicare;
• IU no longer provides group health coverage to any employee;
• when the enrollee's COBRA coverage was extended due to disability and there is a final determination that the enrollee is no longer disabled.

COBRA benefits are provided subject to continued eligibility for coverage. Indiana University and HRPro have the right to terminate COBRA coverage retroactive to the date on which eligibility ends.

Additional Questions?

For questions about COBRA coverage, contact HRPro. They can be reached by email at , or by phone at 248-543-2644, option 3.