Health reimbursement arrangements (HRAs) are subject to COBRA, just like the medical plan. When a member qualifies for COBRA, they can continue to receive the same HRA employer contributions as active employees and must be offered the
opportunity to do so.
Figuring premium is not as easy as dividing annual HRA contribution by 12 and then adding 2%...1 of 2 methods (actuarial or past
cost) are supposed to be used to determine HRA COBRA premium for ex-employees.
The ACTUARIAL METHOD, is used first by assuming a reasonable estimate of the cost of providing HRA coverage to employees and then applying a formula to create a monthly premium. Companies with a newly established HRA must use the actuarial determination method because they have no HRA claim history for the prior year.
With the PAST COST METHOD, calculating the HRA COBRA premiums are based on past HRA expenses and then applying a formula to create the premium.
First of all End Stage Renal Disease (ESRD) creates a couple of key elements related to COBRA. #1 total disability, which adds an 11 month extension to COBRA available coverage and #2 something called a 30 month coordination period, which is essentially the coordination of benefits between a group plan or COBRA and Medicare.
If you are a COBRA eligible participant, you have the same enrollment rights as all active employees. For example, if you were only signed up on Medical but now want to elect Dental, you are able to do so at this time.
Possibly...this really depends on what the court upholds in the divorce decree (meaning the judge may dictate that the member be eligible for COBRA) or the carrier may allow for voluntary termination during a plan year, without a qualifying event.
If neither of those options are created, then the spouse would not be able to continue the benefit through COBRA.
...the spouse or dependent can elect the FSA to be continued through COBRA.
When the COBRA FSA election is made, a second FSA account is created for the beneficiary...the employee still has their FSA account too. Just like any other COBRA plan, the participant must be enrolled in the plan(s) as of the date of the event and also make monthly payments, plus they can terminate an election on a month-to-month basis.
A quick message about late COBRA payments...a Participant has 30 days from the 1st of the month to make their payment. If they don't pay on time, the administrator has the right to terminate the coverage to the last full month of payment.
Sometimes, since the COBRA Participant is usually on the group's bill and they are paying as billed, the Participant's premium is being paid so the Administrator could be lenient and not term, plus accept the "late" payment.
The answer is "yes." This is considered a loss of dependent status and is a qualifying event. If COBRA is elected, the paritcipant can continue coverage for up to 36 months.
Watch our Video on YouTube.
Based on COBRA law and minimum standards requirement, the COBRA participant may have the right to term their coverage mid-plan year and go onto the group plan...only if the carrier, of the group plan, allows it.