Continuation of Health Coverage under COBRA

Continuation of

Health Coverage

under COBRA

COBRA Guide

Plan Year 2024

The Consolidated Omnibus Budget Reconciliation Act (COBRA)

is a federal law requiring large employers to oer employees,

their spouses and dependent children an opportunity to continue

employer-sponsored health coverage following termination of

employment or other events that result in loss of eligibility. UC

oers COBRA rights to domestic partners as well. COBRA allows

you to extend your UC health care benets for a limited time by

paying the full cost of the premium.

There may be more cost-eective options available for you and your family than COBRA continuation coverage. These options

include the Health Insurance Marketplace, Medicaid (called Medi-Cal in California), or other group health plans like a spouse’s plan.

Please note, loss of your UC coverage may create a “Special Enrollment Period” for you to enroll in these other types of coverage;

however, you cannot change from COBRA to a Marketplace or group health plan until the next Open Enrollment period, your CO-

BRA coverage runs out, or you qualify for a Special Enrollment Period another way.

You can access the California Health Insurance Marketplace, Covered California, at www.coveredca.com.

You can access another state’s Health Insurance Marketplace at www.HealthCare.gov.

Table of Contents

How COBRA Works .................................................................. 4

Leave of Absence and COBRA ................................................. 6

Retirement ................................................................................ 7

WEX Health Contact Information ........................................... 8

Important Information ............................................................ 8

Other Important Things to Know about COBRA .................... 8

How COBRA Works

When you’re hired, UC provides an initial general notice that

informs you, your spouse, and any dependent children of the

availability of continuation coverage if you and your family mem-

bers become eligible. The notice will be sent by WEX Health,

UC’s COBRA program administrator, and provides additional

information on COBRA, including your rights and obligations

under the law.

To be a “qualied beneciary” eligible for continuation of cover-

age under the COBRA law, you must be an individual enrolled

in a UC group health plan on the day before you experienced a

“qualifying event” that results in a “loss of coverage.”

WHAT IS A QUALIFYING EVENT?

For the employee:

• Your employment ends for any reason other than gross

misconduct, including retirement separation or permanent

layo.

• Your hours of employment are reduced, including leave of

absence, short work break, and temporary layo, or your

position appointment is changed, resulting in the loss of

benets eligibility.

For the spouse, domestic partner, and dependent children of the

employee:

• The employee loses employment for any reason other than

gross misconduct, including retirement separation.

• The employee experiences a reduction in work hours or

change in appointment resulting in the loss of health care

coverage.

• The employee enrolls in Medicare (Part A, Part B, or both).*

• Divorce, legal separation, annulment of marriage or

termination of domestic partnership. Note: You must notify

UC – see below.

• Death of the employee.

• Dependent child turns 26 years old or legal ward reaches the

age of majority of 18 years old.

*If you are still working and enrolled in a UC-sponsored health insur-

ance, you may delay enrollment in Medicare B. You may qualify for

a “Special Enrollment Period” (SEP)” that will let you sign up for Part

B when you retire or terminate employment.

YOU ARE REQUIRED TO PROVIDE NOTICE FOR CERTAIN

QUALIFYING EVENTS

You must notify the University of California within 60 days of

experiencing divorce, legal separation, annulment or termina-

tion of domestic partnership. You can notify UC within 60 days

of the event by disenrolling your family members from benets

through your online UCPath account to request a COBRA ap-

plication packet. Please note, you may not keep your ineligible

family member on your UC plans.

For all other qualifying events, you do not need to take action;

you will automatically receive a COBRA packet in the mail if you

qualify for COBRA continuation coverage.

WHAT IS LOSS OF COVERAGE?

Loss of coverage means to cease to be covered under the same

terms and conditions as in eect prior to the qualifying event.

Loss of coverage includes the following:

• Termination of coverage.

• Loss of the UC employer contribution, such as while on “direct

bill” status.

• Reduction in benets level, for example, when a reduction in

time moves an employee from Full to Core benets.

WHO IS A QUALIFIED BENEFICIARY?

After a qualifying event that results in loss of coverage, COBRA

continuation coverage must be oered to each person who is

a “qualied beneciary.” You, your spouse/eligible domestic

partner, and your dependent children who are enrolled in eligible

plan(s) become qualied beneciaries if coverage under the

plan(s) is lost due to the qualifying event.

When UC is notied of a qualifying event, COBRA continuation

coverage will be oered to each qualied beneciary. Each quali-

ed beneciary has the right to choose COBRA continuation

coverage. Your spouse, domestic partner or child could elect to

enroll in COBRA without you, the employee, remaining on the

plan.

Example: If John Doe is on an unpaid leave of absence

(LOA), is enrolled in direct billing, and is paying the full

premium for the dental and vision plans, but only paying

the employee portion for the medical plan, then only the

dental and vision plans are subject to COBRA continua-

tion. The medical plan is not subject to COBRA continua-

tion because there is no “loss of coverage.”

How COBRA Works

You may not continue participation in the Dependent Care FSA through

COBRA.

During a disability extension period, premiums may increase from 102% to

150%.

Not making timely COBRA payments does not constitute a qualifying event.

For instance, if your COBRA coverage is terminated due to missed payments,

you cannot use this as a qualifying event to enroll in your spouse’s group health

insurance or the Health Insurance Marketplace. In order to have a Special Enroll-

ment Period, your COBRA maximum coverage period must be exhausted or

another qualifying event must occur (such as starting a new job and becoming

eligible for the employer’s group health insurance). Otherwise, you must wait

until the plan’s open enrollment period to switch to a dierent plan.

If you do not continue coverage under COBRA, you may not keep

your ineligible family members on your UC plans following loss of

coverage. Failure to remove ineligible family members will result

in your liability for any UC costs and plan expenses incurred by

ineligible family members.

WHAT PLANS ARE ELIGIBLE FOR COBRA CONTINUATION?

Qualied beneciaries may continue coverage under COBRA in

the following UC health plans:

• Any medical plan

• Dental PPO and HMO

• Vision

• Health Flexible Spending Account (Health FSA)

• Employee Assistance Program (EAP)

WEX Health is UC’s COBRA administrator. If an individual loses

coverage due to a qualifying event, WEX Health will send them a

COBRA election packet in the mail which includes the “COBRA

Specic Rights Notice Letter.”

Instructions for electing COBRA continuation coverage are pro-

vided in the COBRA packet.

COBRA allows you and your eligible family members to maintain

the same health benets as enrolled in at the time of the qualify-

ing event. You can decide whether to continue each plan individu-

ally, such as opting to continue medical coverage while declining

dental and vision plans.

The qualied beneciary has 60 days from their rst day of

COBRA eligibility or the date their COBRA Specic Rights Notice

was mailed, whichever is later, to make their initial COBRA elec-

tions. Failure to make an election within the 60-day window

will result in qualied beneciaries losing their right to con-

tinue health coverage through COBRA.

COST OF COVERAGE UNDER COBRA

The qualied beneciary is responsible for paying the full plan

premium (UC’s share and the employee’s share) plus a 2%

administrative fee.

Please note that all plan rates are determined

annually and subject to change on an annual basis.

See current COBRA Rates.

Your rst payment is due no later than 45 days after the date of

your election. You may contact WEX Health to conrm the correct

premiums and plans elected. Please note, you are responsible to

ensure that the amount of your rst payment is correct.

Your ongoing monthly payment is due on the rst day of the

month for that month’s coverage period.

You have a 30-day grace period after the start of each coverage

month to make your payment. If you miss making a monthly pay-

ment before the end of the grace period, you will forfeit all rights

to COBRA continuation coverage under the plan.

It is important

to note that the grace period does not apply to the rst payment.

WHEN COVERAGE BEGINS

If you enroll within the 60-day window, your COBRA continuation

coverage begins on the day immediately following the loss of UC-

sponsored employee health coverage due to a qualifying event.

LENGTH OF COBRA CONTINUATION COVERAGE

If elected, COBRA continuation coverage can last for the maxi-

mum continuation period outlined in the COBRA Specic Rights

Notice.

Generally, COBRA continuation coverage is available for up to 18

months if the qualifying event is loss of employment or reduction

in work hours.

If your dependent(s) lose coverage because you divorce, legally

separate, get an annulment, end a domestic partnership or die,

or because the dependent loses eligibility (for example, turns age

26), your dependent generally may continue coverage for up to 36

months.

COBRA CONTINUATION COVERAGE EXTENSION

You may be eligible for an extension of the maximum COBRA

coverage period if you or any other qualied beneciary qualies

for Cal-COBRA, becomes disabled or if a second qualifying event

occurs.

How to Enroll

Example: If your last day of employment with UC is July 2nd,

your employee health coverage will end on July 31st. Upon

electing continued health coverage under COBRA, your ben-

ets through COBRA will become eective August 1st.

How Cobra Works

Cal-COBRA Extension: California law oers an extension of

COBRA, called Cal-COBRA, for fully-insured (UC Blue & Gold

HMO or Kaiser Permanente) medical plans. Participants enrolled

in the UC Blue & Gold HMO or Kaiser Permanente plans may

qualify for an extension of benets up to a total of 36 months.

Please note that extension of coverage under Cal-COBRA is not

available to individuals enrolled in UC’s self-funded plans (CORE,

UC Care, and the UC Health Savings Plan).

Social Security Disability Extension: If you or any other quali-

ed beneciary in your family was determined to be disabled

by the Social Security Administration (SSA) and meets spe-

cic requirements, all qualied beneciaries in that family are

entitled to an 11-month extension, for a total maximum COBRA

period of 29 months. Even if the disabled qualied beneciary

never elects COBRA or chooses to terminate coverage early, all

other qualied beneciaries in that family who remain eligible

for coverage still qualify for the extension.

The requirements are:

• The original qualifying event must be termination of

employment or reduction of hours.

• The date of disability (e.g. the date the qualied beneciary

became disabled) as determined by the SSA must be during

the rst 60 days of COBRA or any time prior.

• The qualied beneciary must notify WEX of their disability

before the end of the original 18-month COBRA continuation

period, even if COBRA ends earlier than the dates listed

below.

• The qualied beneciary must notify WEX of their disability

within 60 days of the following, whichever is latest:

– Date of Notice of Award Letter from SSA

– Date of Qualifying Event

– Date qualied beneciary lost coverage due to qualifying

event (e.g. rst day of COBRA)

– Date of Specic Rights Notice

To apply, you must submit to WEX Health a completed COBRA

Social Security Disability Extension (SSDE) Form along with a

copy of your Notice of Award letter from the SSA.

Second Qualifying Events: A second qualifying event may

include your death, divorce or legal separation, or a dependent

child ceasing to be eligible for coverage under the plan’s deni-

tion of a dependent child (e.g., turning 26 years old). In this case,

the COBRA eligibility period may be extended an additional 18

months, for a total maximum COBRA period of 36 months.

You must notify WEX Health of the second qualifying event

within 60 days of the event.

CHANGES TO YOUR HEALTH PLANS

When you elect COBRA continuation coverage, you will con-

tinue to receive the same health benets you had as an active,

benets-eligible UC employee. Termination of coverage does not

trigger an opportunity to change health plans when you elect

continuation coverage, with one exception: If you lose coverage

due to layo or reduction in time, you may change to the CORE

medical plan if you so choose. In all other situations, you will

need to wait until Open Enrollment to make changes to your

plans or covered family members.

In the event of a qualifying life event such as birth, adoption,

or marriage, you will be given an opportunity to enroll newly

eligible dependents. Contact WEX Health to add newly eligible

family members for the remainder of your COBRA maximum

coverage period.

EARLY TERMINATION

Your COBRA continuation coverage will terminate before the

end date of the maximum continuation period stated in the

Specic Rights Notice if:

• The full premium is not paid on time.

• The qualied beneciary becomes covered under another

group health plan.

• The qualied beneciary becomes entitled to Medicare

benets (Medicare Part A, B, or both) after electing COBRA

continuation coverage.

• During a disability extension, the Social Security

Administration determines that the qualied beneciary is no

longer disabled.

• The University of California ceases to provide any group

health plan for its employees.

LEAVE OF ABSENCE AND COBRA

The type of leave you take determines whether you can continue

active employee health coverage or whether you will need to

consider COBRA continuation coverage or other options.

The Family and Medical Leave Act (FMLA) mandates that em-

ployees on Family Medical Leave (FML) maintain their coverage

in any group health plan under the same terms and conditions as

if they had not taken leave. Therefore, employees on unpaid FML

have the option to maintain benets coverage and pay the em-

ployee share of premiums through Direct Billing with UCPath.

Employees on unpaid leaves that are not protected by FMLA

may be required to pay full premium (UC’s share and the em-

ployee’s share) for medical, dental and vision coverage through

Direct Billing.

It is the qualied beneciary’s responsibility to inform WEX Health if they are

deemed no longer disabled.

For inquiries about Direct Billing, please contact UCPath at

1-855-982-7284. Please note, taking a FML is not a COBRA quali-

fying event, but taking an unpaid leave during which you are

required to pay full premium may trigger COBRA eligibility. Fur-

thermore, coverage termination due to failure to remit payment

timely during Direct Billing is not a COBRA qualifying event. For

more information about FML and leave without pay, see:

Family and Medical Leave Fact Sheet

Leave Without Pay Fact Sheet

RETIREMENT

Retirement is a COBRA qualifying event. When you retire from

the University of California, you will receive a COBRA election

packet in the mail.

If you are eligible for UC retiree health coverage or begin receiv-

ing disability income under University of California Retirement

Plan (UCRP), you may not need COBRA. If you are eligible to

continue your UC coverage under the retiree health program, or

do not otherwise need COBRA continuation coverage, you may

disregard the COBRA notice.

However, if your employee health benets will end in the time

between your separation date and either your retirement date

or the date UCRP disability income is approved, you may need

to continue coverage through COBRA in order to maintain

eligibility for retiree health benets. You must have continuous

coverage to be eligible for retiree health benets. Please consult

with the Retirement Administration Service Center (RASC) for

guidance regarding your individual situation.

If you are ineligible for UC retiree health coverage and/or you

elect a UCRP Lump Sum Cashout, you may maintain UC’s health

plans through COBRA.

After you retire and become eligible for Medicare, you must ap-

ply for Medicare to avoid a late enrollment penalty. Even if you

are covered by COBRA, failure to enroll in Medicare will result

in the late enrollment penalty. This is because COBRA coverage

is not considered “coverage due to current employment,” which

means you won’t qualify for a Medicare Special Enrollment

Period (SEP) for Part B enrollment when your COBRA coverage

ends.

However, coverage under COBRA may be regarded as credit-

able coverage for Medicare Part D purposes. If an individual has

prescription drug coverage through a COBRA plan classied

as “creditable,” they have a SEP to enroll in a Part D plan after

COBRA coverage ends. All of UC’s non-Medicare medical plans

are deemed creditable for Part D.

COBRA ENROLLMENT PRIOR TO MEDICARE

If you become eligible for Medicare after you enroll in COBRA,

your medical plan through COBRA must terminate as soon as

you are notied by the Social Security Administration that you

have been approved for Medicare benets. You will receive a

Medicare Notice in the mail by WEX Health prior to turning 65

with instructions on how you can terminate your COBRA medi-

cal coverage. Please note, you can continue dental and vision

coverages under COBRA.

If you have any dependents who are qualied beneciaries, they

may continue to participate in the same group health plan(s)

through COBRA. Dependents may continue coverage through

COBRA for the remainder of their original coverage period (up

to a total of 18 months).

MEDICARE ENROLLMENT PRIOR TO COBRA

If your Medicare benets were eective prior to your COBRA

election date (retirement date), you may continue both Medicare

and your COBRA continuation coverage. In this case, Medicare

becomes your primary insurance, and the medical plan being

continued through COBRA serves as a secondary insurance.

If you have any dependents who are qualied beneciaries, they

are given an extension of COBRA so that they have a total of 36

months of coverage dating back to the Medicare entitlement

date.

How COBRA Works

Example: You become entitled to Medicare eective

01/01/2024 and then retire eective 11/30/2024. You, your

spouse, and your children remain on the group health plan

until the COBRA qualifying event of retirement. You are not

eligible for UC retiree health benets after retirement.

In this scenario, you are oered 18 months of COBRA start-

ing 12/01/2024. Your spouse and children are oered 25

months of COBRA starting on 12/1/2024, providing them

with a total of 36 months of coverage from your Medicare

entitlement date.

While your maximum COBRA continuation coverage is

through 05/31/2026 (18 months from 12/1/2024), your

spouse and children can continue their health coverage

through 12/31/2026 (36 months from 01/01/2024).

WEX Health

Contact Information

WEX Health Contact Information/Important Information/Other Important Things to Know about COBRA

WEX Health

PO Box 2079

Omaha, NE 68103-2079

1-844-561-1338

https://customer.wexinc.com/login/

You are required to send the COBRA enrollment form and premiums

directly to WEX Health. WEX Health will report eligibility and premi-

ums to your health plan carrier(s).

Important Information

• Notice to Terminating Employees - Health Insurance

Premium Payment (HIPP) Program

• For Persons Disabled by HIV/AIDS CARE/HIPP Program

• FAQs on COBRA Continuation Health Coverage for

Workers

• Federal COBRA and Cal-COBRA

• Medi-Cal Resources

• The Health Insurance Marketplace Contact Information

Covered California

1-877-752-4737

Health Insurance Marketplace (outside of CA)

1-800-318-2596

Other Important Things to

Know About COBRA

ADDRESS CHANGES

It is important that you keep WEX Health informed of any

changes in your address, as it may aect your medical plan

service area. In addition, you might miss important plan infor-

mation if WEX Health has an incorrect address.

OTHER PLANS

For information about continuing coverage in plans that are

not eligible for COBRA, please see the Termination of

Employment Benets fact sheet.

HOW TO APPEAL A CLAIM

If you would like to make an appeal, a written explanation

should be mailed along with any supporting documentation

to:

WEX Health, Inc.

Attention: Appeals

P.O. Box 869

Fargo, ND 58107-0869

Your COBRA Specic Rights Notice letter will include the

above information.

This booklet explains the plan provisions and the policies and rules that govern COBRA. If a conict exists between this booklet and

the UC Group Insurance Regulations, the Group Insurance Regulations govern. The Plan Administrator has the authority to interpret

disputed provisions.

Continuation of

Health Coverage

under COBRA

COBRA Guide

Plan Year 2024

1505 W5/24

By authority of the Regents, University of California Human Resources,

located in Oakland, administers all benet plans in accordance with

applicable plan documents and regulations, custodial agreements,

University of California Group Insurance Regulations, group insurance

contracts, and state and federal laws. No person is authorized to pro-

vide benets information not contained in these source documents,

and information not contained in these source documents cannot

be relied upon as having been authorized by the Regents. Source

documents are available for inspection upon request (800-888-8267).

What is written here does not constitute a guarantee of plan coverage

or benets—particular rules and eligibility requirements must be met

before benets can be received. The University of California intends to

continue the benets described here indenitely; however, the benets

of all employees, retirees, and plan beneciaries are subject to change or

termination at the time of contract renewal or at any other time by the

University or other governing authorities. The University also reserves the

right to determine new premiums, employer contributions and monthly

costs at any time. Health and welfare benets are not accrued or vested

benet entitlements. UC’s contribution toward the monthly cost of the

coverage is determined by UC and may change or stop altogether, and

may be aected by the state of California’s annual budget appropria-

tion. If you belong to an exclusively represented bargaining unit, some

of your benets may dier from the ones described here. For more

information, employees should contact their Human Resources Oce

and retirees should call the Retirement Administration Service Center

(800-888-8267).

In conformance with applicable law and University policy, the University

is an armative action/equal opportunity employer. Please send inquiries

regarding the University’s armative action and equal opportunity

policies for sta to Systemwide AA/EEO Policy Coordinator, University

of California, Oce of the President, 1111 Franklin Street, Oakland,

CA 94607, and for faculty to the Oce of Academic Personnel and

Programs, University of California, Oce of the President,

1111 Franklin Street, Oakland, CA 94607.

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