COBRA Training & Certification Program - Table Of Contents

COBRA Training & Certification Program


  • Issues with COBRA Cost Issues And the Affordable Care Act
  • What Is COBRA?
  • Historical Costs
  • Inception
  • Updates
  • Responsibility
  • Plan Obligations
  • Excise Tax Penalties
  • Contractual Obligations
  • Fiduciary Responsibilities
  • Penalties For Noncompliance With COBRA
  • Issues with COBRA Cost Issues And the Affordable Care Act
  • Coordinating COBRA And The Employer Mandate

Employers And Plans Subject To COBRA

  • Basic Rules For Determining Whether A Plan Or Employer Is Subject To COBRA
  • Defining A Group Health Plan
  • Exceptions
  • Other Exceptions
  • Determining Eligibility Or Exemption: Employees Not Counted
  • Determining Eligibility Or Exemption: Counting Part-Time Employees
  • Determining Eligibility Or Exemption: Typical Business Days
  • Determining Eligibility Or Exemption: Multi-Employer Health Plans
  • Determining Eligibility Or Exemption: Foreign Members of Employers Controlled Groups
  • Determining Eligibility Or Exemption: Compliance Suggestions

Individuals Covered By COBRA

  • Individuals Eligible For COBRA
  • A QBs Rights
  • A QBs Rights: Notification
  • A QBs Rights: Election
  • Other QB "Rights"
  • Who May Not Be A QB, And Who Does Not Have QB Rights
  • Qualified Beneficiaries Located Outside of Plans Service Area

The General (Initial) COBRA Notice

  • The General COBRA Notice
  • The General COBRA Notice Overview: Rights and Responsibilities
  • The General COBRA Notice: Responsibilities of Employees & Qualified Beneficiaries
  • The General COBRA Notice: Employee's Notification Procedures
  • The General COBRA Notice: Content of Employee Notifications
  • The General COBRA Notice: Common Administrative Errors
  • Consequences Of Failure To Provide The General COBRA Notice
  • Suggested Procedure For Sending General COBRA Notice

Qualifying Events

  • About Qualifying Events
  • What May Be A QE
  • What May Not Be A QE
  • Duration Of COBRA Coverage
  • Expanded Coverage For Additional QEs
  • COBRA Notice Rules: Reasonable Notice Procedures
  • QE Issues: Gross Misconduct
  • QE Issues: Disability
  • QE Issues: Disability
  • QE Issues: Cessation Of Dependency Status
  • QE Issues: Cessation Of Dependency Status
  • Suggested Procedures For Managing Cessation Of Dependency Status Issues
  • QE Issues: Divorce Or Legal Separation
  • QE Issues: Divorce Or Legal Separation Notification Requirements
  • Suggested Procedure For Identifying Divorce Or Legal Separation QEs

Qualifying Event Notices

  • Notice Requirements For Employers
  • What QE Notices Should Include
  • To Whom Should QE Notices Be Sent
  • When To Send A QE Notice
  • Suggested Procedure For Sending QE Notices
  • Model Updated Alternative Notice

The COBRA Timeline

  • Defining The COBRA Timeline
  • Understanding & Managing The COBRA Timeline
  • Managing The COBRA Timeline
  • The 14-Day Notification Period
  • The 60-Day Election Period
  • Administrative Tip For The 60-Day Period
  • The 45-Day Retroactive Premium Payment Period
  • The 30 Day Grace Period

Calculating COBRA Premiums

  • COBRA's 12-Month Determination Period
  • Handling Rate Changes
  • Determining COBRA Premiums For Insured Plans
  • Determining COBRA Premiums For Self-Funded Plans
  • Determining Rates For Related QBs Who Independently Elect COBRA
  • Rates For A QBs Newly-Added Spouse Or Dependent

Billing & Collection Options

  • Who To Bill For COBRA Coverage
  • Who Can Pay For COBRA Coverage
  • Internal Billing & Collection Options
  • External Billing & Collection Options

COBRA's Premium Payment Issues

  • Defining Timely Payment
  • Determining If Timely Payment Was Made
  • Partial Payments & Bounced Checks
  • Suggested Procedure For Late And Partial Payments & Bounced Checks
  • Charging For Employer-Subsidized Or Alternative Coverages

Events Terminating COBRA Coverage

  • An Overview Of The Rules Governing Terminating COBRA Coverage
  • Events Terminating COBRA Coverage
  • Natural Expiration Of COBRA Continuation Period
  • Termination Of COBRA Because Of Employer's Cessation Of Health Plan Sponsorship
  • Termination Of COBRA For Failure To Pay Premiums
  • Termination Of COBRA Because Of Other Group Health Plan Coverage Or Medicare Entitlement
  • Termination Of Extended Disability COBRA Coverage Because Of Cessation Of Disabled Status
  • Notice of Unavailability of COBRA Coverage
  • Procedures For Terminating COBRA Coverage

Other Rules & Requirementes

  • Conversion Issues On Termination Of COBRA Coverage
  • Region-Specific HMO Issues
  • Stop-Loss Carrier And Insurance Company Issues With Terminating COBRA Coverage
  • Coordination Of Administrative Resources
  • State COBRA Rules
  • Conversion Coverage Rules
  • Expansion Of COBRAs Loss of Coverage Definition
  • Deductibles, Limits, Split Family Units

Employer Safeguards

  • Summary Plan Descriptions
  • Employer And QB Notification To The Plan Administrator
  • Determining The Start Of The Election Period
  • Issues To Consider For Determining The Start Of The Election Period
  • Responses To Provider Inquiries Concerning Qualified Beneficiaries
  • Handling Coverage During The 60 Day Election Period
  • Suggested Procedure For Handling Coverage During the Election & Payment Periods
  • Providing More Than The Required COBRA Coverage
  • Aggressively Identify QEs
  • Exit Interview Notices And Delivery Systems
  • Keep The Envelopes, Use The Postmarks
  • Affirmative Rejections / Waivers
  • Implement "Use Equals Election" Rules


  • Medicare Basics
  • Medicare: Entitlement vs. Eligibility
  • Suggested Procedure For Determining Medicare Entitlement
  • Medicare As An Initial QE
  • Medicare As A Multiple QE

Open Enrollment

  • Open Enrollment Rights
  • Plan Changes And Their Effect On QBs
  • Open Enrollment Changes By Active Employees Suggesting Possible QEs

Mergers & Acquisitions

  • Mergers, Acquisitions, And Plan Terminations

COBRA And The Family And Medical Leave Act

  • COBRA & The Family And Medical Leave Act

Alternative Coverage Rules

  • Defining Alternative Coverage
  • Alternative Coverage: Consecutive Coverage Method
  • Alternative Coverage: Concurrent Coverage Method
  • Alternative Coverage: Choice Method
  • Selecting An Alternative Coverage Method
  • Implementing The Selected Alternative Coverage Method


  • Introduction
  • Protected Individuals
  • Exceptions To The Five-Year Limit
  • Employee Notice Of Service
  • Nondiscrimination
  • Reemployment Rights
  • Time Limits For Reporting Back To Work
  • Re-Employment Not Required
  • Failure To Timely Report
  • Required Documentation
  • Job Reinstatement Criteria
  • Disability Related To Service
  • Undue Hardship
  • Employee Discharge
  • Health Care
  • Interaction With COBRA
  • Election Notice
  • Health Care Premiums
  • USERRA Extends Beyond 18 Months Of Continuation Coverage
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