COBRA Policy

Summary of COBRA policy

COBRA (Consolidated Omnibus Reconciliation Act of 1985) is a Federal Law which allows benefit eligible employees and their dependents the option of continuing their group health insurance if they lose group health coverage because of a reduction in hours of employment, the termination of employment or a qualifying event.  Under this Federal Law, these employees and their dependents have the right to continue group health care coverage at their own cost plus a 2% COBRA administration fee limited to a specific period of time.

Description of COBRA policy

Employees and dependents may continue coverage for up to 18 months if employment with Villanova University is terminated or there is a reduction in hours of full time employment.

A spouse and dependent children may continue coverage for up to 36 months upon the occurrence of the following events:

  • Coverage is lost because of an employee’s death
  • Divorce or legal separation from the employee
  • Dependent children no longer meet the Plan’s eligibility requirements
  • Employee becomes eligible for Medicare benefits and ceases to participate in the employee-sponsored plan

This coverage is called Continued Coverage and the individuals eligible for coverage are called Qualified Beneficiaries.  Only employees, spouses, and dependent children who are enrolled in the Plan at the time of the qualifying event are eligible for the Continued Coverage.

A Qualified Beneficiary may be subject to more than one Qualifying Event.  Subsequent Qualifying Events may occur as the result of a death, divorce, legal separation, medical enrollment, or a child losing plan eligibility.  A second event may extend coverage to a maximum of 36 months from the date of the original Qualifying Event.

Continued Coverage will end before the maximum time period is reached if:

  • Payments are not paid on a timely basis (within the 30 day grace period)
  • The Qualified Beneficiary becomes enrolled in Medicare Part A Benefits;
  • In the case of a 20 month extension due to certain disabilities, a final determination is made that the individual is no longer disabled (after the first 18 months) or;
  • Villanova University ends its Health and Dental Care Plan coverage for all active employees.

Villanova University, through our COBRA carrier, is responsible for providing you and your dependents with enrollment information for Continued Coverage at the time of the Qualifying Event.  However, if there is a change in your dependent’s status as a result of a divorce, separation, or a child becoming ineligible for coverage, you (or the Qualified Beneficiary), must notify Villanova University of the change within 60 days of the event.  If you fail to notify Villanova University on time, the right to elect continued coverage is lost.  In addition, if disabled individuals wish to continue coverage beyond the original 18 months, they must provide appropriate notice within 60 days of a final determination of disability by the Social Security Administration.

Qualified Beneficiaries are entitled to 60 days to elect his or her own Continued Coverage election.  When coverage is elected, you have 45 days from the date of the election to make any payment.  After that, payments must be made on a monthly basis and there is a 30 day grace period.  Conversion of medical coverage is available only at the expiration of COBRA coverage.

Eligibility for COBRA

All full-time faculty/staff members and their dependents enrolled in benefits are eligible for COBRA.

COBRA Process when you leave the University

Your benefits will continue until the last day of the month in which you resign or are terminated from the University.  Your information will be sent to our COBRA carrier and they will send you a COBRA election notice.  Qualified Beneficiaries are entitled to 60 days to elect his or her own Continued Coverage election.  When coverage is elected, you have 45 days from the date of the election to make any payment.  After that, payments must be made on a monthly basis and there is a 30 day grace period.

COBRA Process when you have a qualified life event

If there is a change in your dependent’s status as a result of a divorce, separation, or a child becoming ineligible for coverage, you (or the Qualified Beneficiary) must notify Villanova University of the change within 60 days of the event.  Qualified Beneficiaries are entitled to 60 days to elect his or her own Continued Coverage election.  When coverage is elected, you have 45 days from the date of the election to make any payment.  After that, payments must be made on a monthly basis and there is a 30 day grace period.

COBRA Process when you go onto Long Term Disability

When a faculty/staff member has been approved to receive LTD benefits, all salary and payroll deductions from the University will end.

Continued coverage for medical, dental, health care flexible spending account (FSA) and Employee Assistance Plan (EAP) coverage is available under COBRA. The length of the COBRA period is dependent upon the qualifying reason. Generally, COBRA coverage may be continued for up to eighteen (18) months. If a faculty/staff member under age 65 on the LTD benefit effective date, and is determined by the Social Security Administration (SSA) to have been disabled, they may qualify to receive up to an additional eleven (11) months of COBRA coverage, for a maximum of twenty-nine (29) months. The first twenty-four (24) months of the COBRA period, providing the faculty/staff member applies for and is qualified for the COBRA disability extension, will be billed at the faculty/staff rate plus a 2% COBRA administration fee for the coverage and level, for which the faculty/staff member is currently enrolled. However, if the faculty/staff member turns age 65 during the COBRA period, they are required to apply for Medicare coverage. Applications for Medicare must be made at least two (2) months prior to the Medicare effective date. Information regarding COBRA will be mailed directly from CONEXIS, the University’s COBRA administrator. Also, information regarding conversion of the faculty/staff member’s current life insurance coverage will be sent directly from the University’s life insurance provider.

If a faculty/staff member is over age 65 on the LTD benefits effective date, and is determined by the Social Security Administration (SSA) to have been disabled, they may qualify to receive up to an additional eleven (11) months of COBRA coverage, for a maximum of twenty-nine (29) months. The first twenty-four (24) months of the COBRA period, providing the faculty/staff member applies for and is qualified for the COBRA disability extension, will be billed at the faculty/staff rate plus a 2% COBRA administration fee for the coverage and level, for which the faculty/staff member is currently enrolled. However, they will have an eight (8) month period to elect Medicare coverage from their LTD benefits effective date. If Medicare coverage is not elected within the eight (8) month election period, Medicare may be elected in the future, but will be subject to the late enrollment penalty. In order to avoid this on-going penalty, Medicare coverage must be elected when first eligible for coverage.

 

In the event of any discrepancy between the plan documents and this retirement policy, the plan documents always govern.