BN - FAQ COBRA Continuation Notice Process
The COBRA/Continuation Notice process (Process) has been centralized and is the responsibility of the UWSA Service Center (UWSC). The specific language in the Notice is determined by Job Data Action/Reason Codes.
What generates a COBRA Notice?
Job changes entered into HRS Job Data or life events entered through ADM events for removal of dependents causing non-voluntary cancellation of benefits will generate COBRA/Continuation Notices (Notices). Notices will include information for all benefit plans the employee (or dependents) are enrolled in. Events that will generate COBRA/Continuation Notices:1. Termination of employment
2. Movement Between Benefited to LMT Appointment
3. Involuntary dependent removal
When are COBRA Notices printed?
Notices are printed, dated and mailed the next day.
If entered on Friday, the notice will be printed, dated and mailed on Monday. Allow for holidays. The notices are available in Cypress the day they are generated. Notices are available for 3 month in Cypress then archived. If you need an archived Notice, contact your Affinity Group to create a ticket
Where can I see an employee’s COBRA Notice?
Cypress under Prod > UWSC – HRS > COBRA folder
How does Benefit Administrator entry drive COBRA? What is the COBRA process logic?
Notices are created based on the “Election Date” and “Deduction Begin Date” less than current system date on the Enroll in Benefits screens. ADM, MSC, and Job Data events should be entered and finalized timely. Future events should not be finalized more than 90 days in advance; otherwise, the employee will be missed in the process due to ‘Election Date’ being outside of the established criteria.
What is the difference between a COBRA Notice and COBRA forms?
The COBRA Notice is an automatically generated notice informing employees of their Loss of Coverage and their rights following Loss of Coverage. The actual COBRA/Continuation forms are not provided with the Notice. The employee or dependent will be directed to contact the UWSC for the forms. The date on the forms will be the date of the Notice (or amended Notice). The UWSC will create and mail the forms to the requester. The requester must meet the deadline for submitting the forms to the vendors. So it is essential that the forms are requested in a timely manner.
Who is the official record keeper of COBRA Notices?
The UWSC is the official record keeper of the Notices. Institutions should follow their record retention guidelines regarding maintaining courtesy copies.
Who counsels the employee?
Institutions need to continue their general exiting responsibilities, such as benefit counseling, collecting new home address and updating HRS, and reviewing the employee for age and number of years of WRS (local and state) service to determine if a sick leave certification needs to be submitted to Employee Trust Funds.
If the employee is eligible for sick leave credit and over the retirement age and has not indicated they are retiring, it is best practice to remind the employee to submit a Sick Leave Credit Escrow Application, ET-4305, so they do not lose the sick leave credit. If under the retirement age with 20 or more years of WRS (local and state) service the employee’s sick leave is automatically preserved, and no Escrow application is required. The institution is responsible for submitting the sick leave certification upon termination.
What is best practice for ADM entry and Job Data Entry?
It is very important that the institution uses the correct Enrollment Code/Enrollment Reason in On-Demand for ADM events so that the Notice is created.
Use the following Enrollment Code/Reason(s):1. Remove Dependent - DivorceEvents in Job Data that trigger the termination of insurances must also have the correct Action and Reason codes so the insurance is terminated correctly.
2. Remove Dependent - Grandchild’s Parent Turns 181. Termination
2. Layoffs (use any ‘Layoff’ Job Data Action/Reasons or ‘Retirement in lieu of Layoff’)
3. Movement from Benefited to LMT Appointments
What benefits are not eligible for COBRA?
ICI, WRS, and FSA Dependent Care are not COBRA eligible plans.
What benefit plans are not included in COBRA Notices due to specific events?
Divorce: If State Group Life (SGL) Spouse/Dependent and/or Individual and Family Life coverage is not removed, then a COBRA will not be received. An employee will need to submit application to remove these coverages.
Retirements: Do not include SGH or SGL. ETF administers these benefits for retirees.
What if the dependent has a different address than the employee?
If the employee provides the address of the dependent(s), the institution must update the Dependent/Beneficiary screen Address tab prior to the Notice being generated. If the dependent has a different address than the employee, the Notice will be sent to the dependent’s address.
An employee didn’t receive their COBRA Notice. Now what?
1. Check their mailing address
2. Go to Cypress and print out a copy and send to the employee
3. If it is discovered a Notice was not provided, and there are still eligible months remaining in the COBRA/Continuation period, we are required to send the standard NOTICE at time of discovery. The individual will be eligible for the remaining period. (Exception: Life insurance plans require receipt of form within 31 days of loss of coverage.)
How do I request an amended COBRA Notice?
The UW is legally obligated to send out an amended Notice for:1. Incorrect Job Termination ReasonContact their Affinity Group to create a ticket. An amended Notice will be created by the UWSC Benefits team.
2. Late entry into HRS for insurance changes after termination
3. Incorrect Termination Date
4. Divorce dates change
Please do not reprocess the event.
When will an Age 26 dependent receive a COBRA Notice?
1. Process creates a 90-day letter generated on the first of the month, then printed and mailed to the employee. No forms are generated.
2. Process creates a 30-day letter generated on the first of the month, then printed and mailed to the employee. No forms are generated.a. The program will also generate a letter for dependents entered after the initial 90 day run for their birth month.
3. COBRA Notices to the Adult Child will be available in Cypress the first week of the month they turn 26.
4. NOTE: In cases of disabled adult children, please refer to KB BN - Adult Child Disability Process.
Who are the Letters Addressed to?
- Letters are addressed to employees for Termination, Retirement, and Layoff.
- Letters for divorce are addressed to ex-spouse (and any children who may be removed from the Divorce as well). Only one letter is generated for both ex-spouse and child(ren).
- Letters are addressed to the employee for their dependent child(ren) losing coverage due to Age 26.
- Letters are addressed to employee for their dependent child(ren) losing coverage due to Grandchild’s Parent Turns Age 18