Remembering COBRA Participants During Open Enrollment

With so much information to communicate to your employees, including benefits plan updates and answers to HR-related questions, it’s easy to forget things during the open enrollment period every year.

Here’s your reminder to not forget about your company’s COBRA participants.

The proverbial out of sight out of mind. They usually aren’t current employees, so you likely don’t see them or even interact with them on a regular basis, but depending on the circumstances may be an even larger group this year. However, according to federal law, COBRA participants have their rights, too.

Who are COBRA participants?

When a qualified employee leaves a company and loses employer-sponsored health benefits, the employer is required by law to offer continuation coverage. If an individual signs up for COBRA coverage, the employer is then required to offer the same benefit plans to that individual during the open enrollment period.

While these individuals aren’t at your company, they’re still part of the benefit plan. That can also include any spouses and dependent children who were on the participant’s health plan.

What exactly is required?

According to the U.S. Department of Labor, employers are required to offer qualified individuals coverage that is identical to what is offered to active employees, including dental and vision coverage. Additionally, any benefit plan changes also apply to COBRA participants.

Why you shouldn’t forget

There’s a pretty compelling reason why your organization shouldn’t forget about your COBRA participants: money.

The current law states employers that aren’t in compliance with offering plans to COBRA participants are subject to fines and other penalties. Beyond that, it can also create massive headaches for COBRA participants who could lose their coverage at the beginning of the new plan year.  Also, you may not be able to adjust for cost changes to the plans, if you miss an open enrollment period for this group of participants. Generally plans must fix premiums before each 12-month premium cycle.

Ensure you’re compliant

Open enrollment can be a confusing, stressful and tedious time. Chances are you’re already double- or triple-checking plan updates and confirming which employees are eligible and which ones still haven’t completed their enrollment.

Adding your COBRA participants to the checklist will create a healthy habit so you don’t forget them, while ensuring your company offers what is required by federal law. The sooner you check on this, the better.

How to Most Effectively Communicate with COBRA Participants

Depending on your COBRA population, it may be beneficial to offer an open enrollment meeting to the COBRA participants. Don’t forget that you may have to perform enrollments on paper, as the COBRA participants may not be able to enroll within a Benefits Administration System or HRIS.

Consider using email and traditional mailers to reach participants. If you are using a TPA for COBRA participants, do not forget how that TPA is communicating the new plan details and costs to the participants, as well as ensuring that the cost updates have been added to the system of choice.