COBRA

COBRA administration

Your school will now be responsible for COBRA administration as it relates to anyone with DENTAL coverage. Remember this does not change the COBRA administration for Medical/Rx benefits which is handled by Independent Health/NOVA or MVP accordingly.

It is each schools’ responsibility to be sure they are using the most up-to-date COBRA information. Please visit the following Department of Labor pages below to ensure compliance.

DOL Website General Guidance: https://www.dol.gov/general/topic/health-plans/cobra

DOL Website Model Notices: http://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra

To assist schools in COBRA administration, necessary required forms as well as some helpful guides can be found in the Resources section.

Below are descriptions and instructions to complete each form.

COBRA Election Cover Letter (COVID Extension)

This letter should accompany the COBRA Model Election Notice. This letter is temporary due to COVID, but outlines the extensions that were implemented by the IRS and DOL. You will need to complete:

1. Date of the letter
2. Name and address of the COBRA eligible participant (this could be the employee, dependent or both depending on the reason for loss of coverage.)
3. At the bottom fill in the school contact name and phone number as indicated

The Trust will inform you when there is no longer a need to use this Cover Letter.

COBRA Model Election Notice

This is the COBRA Election notice that should be sent to any individual who loses dental coverage. The first page is instructions by the Dept of Labor (DOL) and should not be sent to the participant. Starting on page 1, you will have to:

- Page 1, complete date of notice and address to the name of COBRA continuant (could be the employee or dependent).
- Page 1, complete the reason for COBRA notice (under the Why am I getting this notice?) Be sure to include the date coverage ends (qualifying event date) and then check the appropriate box for the reason of loss of coverage.
- Page 1 and 2, complete the “qualified beneficiaries” section. If the coverage was terminated for employee and dependents, be sure to check all applicable boxes.
- Page 2, complete the “If I elect COBRA continuation…” section and fill in the date boxes as indicated with [italics] which include the length of COBRA coverage.
- Page 2, complete the “Can I extend the length….”section and fill in the SCHOOL NAME for the [party responsible for COBRA administration].
- Page 3, under the next section “How much does COBRA…”, enter the amount of the dental premium and you can include a 2% fee for the school’s cost to administer.
- On Page 5, under “For more information”, again include the SCHOOL, phone number and address as the [party responsible for COBRA administration].
- Page 7, In the Instruction box, include the SCHOOL name and address for where to send the completed form, the due date and the manner in which to submit the form.
- Page 8, under Information About Payment, include the SCHOOL, phone number and address for who to contact for payment information, and where to send payment.

NOTE: The election notice describes the rights to continuation coverage and explains how to make an election. The plan administrator must furnish an election notice to each qualified beneficiary–the covered employee, covered spouse, and any covered dependent child–who loses plan coverage in connection with the qualifying event. The election notice must be provided to the qualified beneficiaries within 14 days after the plan administrator receives the notice of a qualifying event.

COBRA Model General Notice

This is the notice that should be provided to all new hires. The first page is instructions by the Dept of Labor (DOL) and should not be sent to the participant. Starting on Page 2, you will have to:

1. Page 2, “When is COBRA continuation available?” complete the [italics sections] marked by highlights as applicable.
2. Page 3, under “Plan Contact” include the School Name, address, phone number and contact person.

NOTE: The general notice describes general COBRA rights and employee obligations. This notice must be provided to each covered employee and each covered spouse of an employee who becomes covered under the plan. The notice must be provided within the first 90 days of coverage under the group health plan.