Administrative Information

COBRA Continuation Coverage

If health care coverage for you or an eligible dependent ends for one of the reasons described in this section, you may be able to continue your coverage for a limited period under the Consolidated Omnibus Budget Reconciliation Act (COBRA).

You may elect COBRA continuation if your coverage ends under one or more of the following plans: 

  • Medical Plan
  • Dental Plan
  • BeWell Center Onsite Clinic Access*
  • EyeMed Vision Care Plan
  • Health Care Flexible Spending Account 

*Temporary employees are eligible for BeWell Clinic COBRA continuation coverage only if they were paid via the Company payroll and enrolled in a Company-sponsored medical and/or dental plan prior to the date that their coverage would otherwise have ended. 

QUALIFYING EVENTS
A covered person becomes eligible for COBRA continuation coverage if he or she experiences a qualifying event. A qualifying event is defined as: 

  • your death;
  • your termination of employment for any reason other than gross misconduct;
  • a reduction in your work hours;
  • your divorce or legal separation;
  • an eligible dependent’s loss of coverage due to your becoming entitled to Medicare; or
  • your dependent child’s coverage ends because he or she no longer meets the definition of “eligible dependent” (for example, due to age).

Birth or Adoption: For COBRA purposes, an “eligible dependent” includes a child who is born or adopted after you became eligible for COBRA continuation coverage. 

It is your responsibility to notify the COBRA Administrator concerning a divorce, legal separation, or the loss of a dependent child’s eligibility under the plan. This notice must be provided within 60 days of the date that the qualifying event (e.g. divorce) occurs. This is explained under Notification and Election Period (see below).

COST OF COBRA COVERAGE
You or the other covered person (if applicable) must pay the entire premium* for COBRA coverage. This premium includes the amount that the Company would otherwise have paid on your behalf, and is equal to 102% of the cost of plan coverage. 

*If you are involuntarily terminated (for reasons other than gross misconduct), you should contact the COBRA Administrator concerning your eligibility (if any) for partially subsidized COBRA premiums. 

DURATION OF COBRA COVERAGE
A person who is eligible for COBRA continuation coverage is called a qualified beneficiary. As the following table shows, the duration of COBRA coverage depends on the nature of the qualifying event: 

DURATION OF COBRA COVERAGE
 Qualifying Event  Qualified Beneficiaries Maximum Period of Coverage
  • Termination of employment for any reason other than gross misconduct
  • Reduction in work hours
Employee, spouse*, and eligible dependent children

18 months

Military service (see discussion below)

Spouse* and eligible dependent children

24 months

  • Divorce or legal separation
  • Employee's entitlement to Medicare
  • Employee’s death
Spouse* and eligible dependent children

36 months

Dependent child loses coverage because he or she is no longer an “eligible dependent” Dependent child

36 months

Disability Extension: You or another qualified beneficiary may be eligible for up to an additional 11 months of COBRA continuation coverage (for a total of 29 months’ coverage) if you or the other qualified beneficiary is determined by Social Security to be disabled: 

  • at the time your termination of employment occurs; or
  • within 60 days of the date that you became eligible for COBRA coverage.

*Including same-sex spouses and qualified domestic partners

Second Qualifying Event
Generally, COBRA coverage is available for a maximum of 18 months for employment termination or reduction of work hours. This period may be extended for your spouse and eligible dependent children in the event of: 

  • your death during the 18-month continuation period; or
  • your divorce or legal separation during the 18-month continuation period. 

The maximum period of COBRA continuation coverage (including any extension for the reasons listed above) is 36 months. This 36-month period is measured from the date of the first qualifying event (i.e., the event that originally gave rise to COBRA coverage). 

Military Service
The spouse and eligible dependent children of Tufts Health Plan employees who voluntarily or involuntarily go on active duty with the Armed Forces of the United States are eligible for up to 24 months of COBRA continuation coverage. For example, this would apply if you are an employee reservist who is called to active duty.

For more information on veterans’ benefit and reemployment rights, see USERRA. 

Pre-existing Condition
COBRA continuation coverage for you or another qualified beneficiary ends when you or the other person becomes covered under another group health plan. However, a special rule applies if:

  • you or the other covered person becomes covered by another health plan; and
  • that plan contains a pre-existing condition limitation or exclusion that affects you or the other covered person.

In the above case: 

  • the affected person’s COBRA continuation coverage may be continued until the date that it would otherwise have ended; provided that
  • the Tufts medical plan will be the primary provider for the pre-existing condition only and the secondary provider for all other services covered by the plan. 

WHEN COBRA COVERAGE ENDS
COBRA continuation coverage will end at the end of the maximum period of coverage, which in most cases is 18 or 36 months from the date of the qualifying event. However, COBRA coverage may end earlier if:

  • your COBRA coverage premiums are not paid on a timely basis;
  • you or another qualified beneficiary becomes entitled to Medicare* or becomes covered by another group health plan* that does not contain a pre-existing condition exclusion (see above).
  • the Company discontinues all Company-sponsored group health plans. 

*This applies only if you or the other covered person becomes entitled to Medicare or covered by another group health plan after COBRA continuation coverage has been elected

NOTIFICATION AND ELECTION PERIOD
You or your qualified beneficiary (if applicable) will receive a written notice of the right to elect COBRA continuation coverage if: 

  • you terminate employment;
  • you are affected by a layoff or reduction in work hours;
  • your death occurs during active employment; or
  • you become entitled to Medicare. 
Please remember that it is your responsibility to notify the COBRA Administrator concerning a divorce, legal separation, or loss of a dependent child's eligibility status under your Tufts health care plan. This notification should be provided to the COBRA Administrator within 60 days of the date that the qualifying event (e.g., divorce) occurs. You or the other covered person (if applicable) will then receive a written notice of the right to elect COBRA continuation coverage. 

Election Period
If your Tufts Health Plan coverage ends for one of the above reasons, you may elect to continue your coverage by contacting the COBRA Administrator within 60 days* of the date that your coverage would otherwise have ended (or within 60 days of the date you receive notification of your right to elect continued coverage, if later).

If you (or the other covered person, if applicable) do not choose to continue coverage within the 60-day* election period, the right to elect COBRA continuation coverage will end. 

*If you are involuntarily terminated (for reasons other than gross misconduct), the COBRA Administrator will notify you concerning your eligibility (if any) for an extension of this 60-day election period. You can contact the COBRA Administrator if you have any questions about your COBRA election period and when it ends. 

TRADE-DISPLACED WORKERS
Special COBRA rights apply to employees who have been terminated or experienced a reduction of hours and who qualify for a “trade readjustment allowance” or “alternative trade adjustment assistance” under a federal law called the Trade Act of 2002. These employees are entitled to a second opportunity to elect COBRA coverage for themselves and certain family members (if they did not already elect COBRA coverage), but only within a limited period of 60 days (or less) and only during the six months immediately after their Tufts Health Plan coverage ended. 

If you qualify or may qualify for assistance under the Trade Act of 2002, contact the COBRA Administrator for additional information. You must contact the COBRA Administrator promptly after qualifying for assistance under the Trade Act of 2002 or you will lose your special COBRA rights.