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Processing the Age 26 Dependent COBRA Continuation Notification Process in HRS
OverviewThis document outlines the Age 26 Adult Child COBRA Notification process for State Group Health, dental and vision benefits continuation. This process has been centralized with the administrative functions being completed by UW Shared Services (UWSS). This document focuses on the responsibilities of the institutions.
Under the federal COBRA law, employees and their qualified beneficiaries may continue health insurance coverage. The maximum period of continuation coverage for a qualifying event is:
- 18 months after employee’s termination for the employee, spouse, Chapter 40 domestic partner or dependent child(ren);
- 36 months after employee’s divorce/termination of Chapter 40 domestic partnership for the spouse/domestic partner or dependent child(ren);
- 36 months after employee’s death for the spouse/domestic partner or dependent child;
- 36 months after the dependent child's loss of eligibility under the plan.
- Once an employee’s adult child is no longer considered their dependent for benefit purposes, actions must be taken to remove the child from the employee’s benefit plans. Adult child(ren) who are no longer eligible for health, dental and/or vision are removed from the plans at the end of the month they turn age 26.
- During the first week of each month, UWSS will update the Dependent/Beneficiary screen in HRS by changing the relationship from Child to Adult Child effective the first of the month following their 26th birth date. UWSS will also create an ADM event in HRS for the first of the month following dependent's 26th birth date. Dependent will be removed from all insurances on the health enrollment screen (health, dental, and vision) and coverage level will be changed, if appropriate.
- When the ADM is finalized (Enrollment Code: Remove Dependent, Enrollment Reason: Age 26 Dependent) the COBRA Notification process will run and create a COBRA Notice to the dependent.
- UWSS will run the Age 26 Process on the 1st of each month and generate letters for all campuses, producing two set of letters:
- 90 day letters are prepared and mailed 90 days in advance, on or before the 1st of the month. These letters are directed to both the dependent and the employee. They are mailed to the employee’s last known address with the expectation the parent will forward the information to the dependent. No COBRA/Continuation forms are included.
- 30 day letters are generated, printed, and mailed to the employee only on the 1st of the month in which their adult child birth date occurs. No COBRA/Continuation forms are included.
- Applications are not required to remove an adult child from insurances.
- Copies of COBRA notices will be in Cypress for the institution.
- Path: Cypress > PROD > UWSC - HRS > COBRA folder. Click on Title row to put in alpha order > COBRA Age 26 letters created Month/Day/Year.
- ETF will automatically remove any Age 26 adult children from the health plan at the end of the month in which they turn 26, even if HRS has not been updated through an ADM event indicating Remove Dependent - Age 26 Dependent.
- If the final adult child/dependent is dropping from the health plan, ETF will not change the health coverage from family to single until UWSS enters and finalizes the ADM event in HRS indicating Remove Dependent - Fam to Single - Final Dep 26.
- The electronic files to Vision and Dental will update the same information for these plan providers.
Actions Required by Institutions1. Review the 90 day and 30 day letters and the COBRA notices for accuracy and file them in the employee’s benefit folder. Follow your campus' Record Retention policy.
- If an error is found, please contact UWSS to start a ticket. UWSS will be responsible for creating an amended COBRA Notice and providing a copy to institution.
- File a copy of the amended COBRA Notice in the employee benefit folder and maintain per your institutions Record Retention policy.
2. If the employee contacts the institution with a corrected birthdate, the Benefit Administrator must obtain a birth certificate from the employee.
- Update the birthdate on the HRS Benefits > Employee/Dependent Information > Update Dependents/Beneficiary screen (See: Adding and Updating Dependents in HRS) and re-enroll the dependent on the HRS Benefits > Enroll In Benefits > Health Benefits screens (See Enrolling, Changing, or Canceling Coverage Using On Demand Event Maintenance in HRS).
- Fax a copy of the birth certificate to UWSS. UWSS will update the birthdate with the vendors.
3. If the employee contacts the institution asking about having their adult child approved as either:
- A disabled adult – follow KB: Adult Child Disability Process
- A full-time student called to Federal Active Duty while under the age of 27 and while attending, on a full-time basis, an institution of higher education. The adult child must apply to an institution of higher education as a full-time student within 12 months from the date the adult child fulfilled his or her active duty obligation. (Please contact UWSS for required documentation.)
- If the coverage level is changing do to the removal of the adult child and the employee submits an application, the institution is responsible for creating the ADM in HRS and changing the coverage level. The institution is responsible for sending the Conversion form to the employee. The COBRA Notice process will not include these.
- If applications are not submitted timely, there are limitations on refunding premiums. See Child Loses Dependent Status Due to Age chart.
- State Group Life provides Spouse/Dependent (S/D) coverage and requires the employer to provide a Conversion form when the coverage terminates.
- Since HRS does not keep track of dependents on the life enrollment screen in HRS, UWSS will not know to send a conversion form unless the employee informs us to.
- The employee only submits an application to cancel S/D coverage if the adult child is the last dependent and they no longer need the S/D coverage at all.
- AD&D provides family coverage and requires the employer to provide a Conversion form when the coverage terminates.
- Since HRS does not keep track of dependents on the Life enrollment screen in HRS, UWSS will not know to send a conversion form unless the employee informs us to.
- The employee only submits an application to change the coverage level to Employee Only Coverage if the adult child is the last dependent and they no longer need the Family Plan.
- Individual & Family Group Life provides child(ren) coverage and requires the employer to provide a Conversion form when the coverage terminates.
- An eligible dependent child is 15 days or older and will remain so until the last day of the calendar year in which they attain the age of 25.
- Since we do not keep track of dependents on the Life enrollment screen in HRS, we will not know to send a conversion form unless the employee informs us to.
- The employee only submits an application to cancel the child(ren) coverage if the adult child is the last child dependent and they no longer need the child(ren) coverage at all.
- Since this coverage only goes through age 25, if the employee did not notify you the year before, you are no longer required to send the Conversion form.
- Adding and Updating Dependents in HRS
- Enrolling, Changing, or Canceling Coverage Using On Demand Event Maintenance in HRS
- Requesting Adult Child Disability Approval