The following is excerpted from our COBRA Training & Certification Program:

Suggested Procedures For Terminating COBRA Coverage

COBRA notice rules require that the plan notify QBs if COBRA coverage will be terminated earlier than the maximum period applicable to the qualifying event. The notice of termination must contain the following information:

• The reason COBRA has terminated earlier than the end of the maximum period
• The date of termination
• Any rights the QB may have under the plan or other applicable law to elect alternative or individual coverage (such as conversion coverage)

This notice must be furnished as soon as practicable following the determination that the QB is no longer entitled to COBRA.

Suggested Procedural Steps:

In cases where termination of COBRA continuation coverage is permitted for reasons other than non-payment or incomplete payment of COBRA premiums:

• Immediately terminate coverage on the relevant date
• Promptly send a notice to the QB stating that his or her COBRA continuation coverage has terminated, stating the reason the coverage terminated, and stating the date on which the coverage terminated
• Code its plan's administrative system to show the QB as a "terminated" participant

If the reason for the termination of coverage is the non-payment of premiums or the payment of a premium that is short by an insignificant amount:

• The employer must be sure to code its plan's administrative system to show the QB as "terminated but within grace period" until the applicable 30 day grace period expires
• As soon as the applicable 30-day period has expired, the employer should send a written notice to the QB stating that his or her COBRA continuation coverage has terminated for non-payment of premiums and stating the date on which the coverage terminated
• Code its plan's administrative system to show the QB as a "terminated" participant

Related Links

• ADA Training & Certification Program
• FMLA Training & Certification Program
• COBRA Training & Certification Program
• Integrating FMLA, ADA, COBRA & Workers' Comp Training & Certification Program
• FMLA & ADA Certificate Program