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COBRA Enrollment and Your Rights

I received a letter with a COBRA enrollment form in the mail. What do I need to do with it?
You’ve received this letter because you’ve lost your health insurance coverage due to a
qualifying event. If you wish to enroll in COBRA, the COBRA enrollment form must be completed and returned within 60 days of the notification date printed on the letter or 60 days from the loss of coverage, whichever is later. Even if you do not plan to enroll in COBRA, we recommend that you save the enrollment form for the entire 60 days.

How do I enroll?
To enroll in COBRA, your completed enrollment form must be postmarked or faxed to ADP within 60 days of the notification date or loss of coverage as noted in the enrollment package.

*To ensure a speedy enrollment, please complete these instructions:

  • Sign where indicated.
  • Provide your dependents’ information as indicated.
  • Indicate the coverage you want.
  • Make the first premium payment within 45 days of enrollment.
  • Mail your completed enrollment form to the address indicated on the form.
  • If including your first premium payment, mail payment only to:
P.O. Box 105413
Atlanta, GA 30348-5413

Please allow 10-14 days for ADP to process your enrollment. Also allow for an additional 10-14 business days after posting of your payment for your health insurance provider to update your insurance coverage.

*Submitting an enrollment form and/or payment does not guarantee COBRA coverage. Please refer to your general COBRA notice, your plan documents, and/or your COBRA election notice for information regarding coverage.

How is COBRA different than my regular health insurance?
Your former employer no longer pays a portion of the premium, and your portion of the premium is no longer deducted from your paycheck. Therefore, you must pay the entire premium plus a 2% administrative fee. Coverage is on a month-to-month basis and payment is due at the first of each month.

Why haven’t I received my COBRA enrollment?
The employer has 30 days to send out the information to the billing administrator when a qualifying event has occurred. The billing administrator has 14 days to process the information and send out a notification to the participant.

When is my COBRA coverage active?
Your coverage will be active when all of the following has occurred:

  1. The COBRA enrollment form has been fully completed, signed and received by ADP.
  2. The first premium payment has been received by ADP, posted to your account, and forwarded to your insurance carrier.
  3. Your insurance company has accepted your enrollment and has updated its records.
Receipt of your payment after the first of each month may impact continuous coverage at the carrier.

Who is ADP and why am I paying them?
ADP is a third-party administrator hired by your former employer to process your COBRA enrollment, collect your insurance premiums, and forward those premiums to your insurance carrier. With more than 24 years experience in COBRA administration and a dedicated internal compliance team, you can rest assured that you’re receiving all COBRA privileges required by law.

When am I eligible for COBRA?
Generally, when you, your spouse* or another eligible dependent loses group coverage due to:

  • Job termination (whether voluntary or involuntary) or a reduction in hours of employment.
  • Divorce or legal separation.
  • Retirement.
  • Medicare entitlement.
  • Certain leaves of absence.
  • No longer covered by parents’ insurance.
*Federal law does not extend COBRA coverage to domestic or same-sex partners.

When am I not eligible for COBRA?
Generally, you’re not eligible when:

  • Job termination was due to gross misconduct, as determined by your former employer.
  • Your former employer has less than 20 employees.
  • You don’t submit your enrollment form within the required deadline.
  • You don’t remit your first premium payment within the required deadline.
  • You are not enrolled in a group health plan while an active employee.
  • You lost your coverage due to a divorce and you did not notify your employer (or your spouse's former employer) of your divorce within the required notification timeframe.

Are there any special considerations for military leave?
Federal COBRA does not require any special treatment for those individuals on military leave. However, the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) provided for the continuation of health plan coverage for up to 18 months for those persons on military leave. Because this overlaps with COBRA, military leave was treated the same as COBRA.

In December of 2004, the Veterans Benefits Improvement Act of 2004 (VBIA) amended USERRA to extend health plan coverage up to a total of 24 months. Because this is longer than the 18 months allowed by COBRA, military leave beginning on or after December 10, 2004 may need to be treated differently than COBRA. Please contact your HR office to learn your employer’s specific policy for coverage continuation during military leave.

How does a pre-existing condition clause affect me?
Depending upon the terms of the plan, a pre-existing condition is any medical condition that was present or that has been diagnosed or treated within a specified period before the effective date of the health plan coverage. With the passage of HIPAA in 1996, pre-existing conditions can’t be considered when an insured changes or loses a job unless the insured has had a break in insurance coverage of 63 days or more, assuming the insured has had the coverage for a sufficient length of time.

This means that a new insurance plan may not cover conditions, such as asthma, heart disease, diabetes, pregnancy or any other illness or injury diagnosed or treated while you did not have health insurance. Having COBRA coverage may protect you against a pre-existing condition clause.

What is HIPAA?
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) provides expanded rights and protections for participants and beneficiaries in group health plans. Understanding these rights is important to your decisions about future health coverage. If you find a new job that offers health coverage, or if you are eligible for coverage under a family member's employment-based plan, HIPAA includes protections for coverage under group health plans that:

  • Limit exclusions for pre-existing conditions.
  • Prohibit discrimination against employees and dependents based on their health status.

ADP cannot provide you with any guidance regarding the provisions of the plan. Please refer to the appropriate plan documents for more information on how that plan’s provisions will apply to you.

What is a HIPAA certificate of creditable coverage? And what is it used for?
If requested to do so by your former employer, ADP will provide you with a HIPAA certificate to verify continuous coverage through COBRA and the length of that coverage. This certificate is issued as documentation of your prior health insurance coverage. Give a copy of your HIPAA certificate to your new employer’s health insurance plan administrator to offset any pre-existing condition clauses and to verify you had no lapse in coverage.

What kind of insurance coverage can be continued under COBRA?
Generally medical, dental, vision, prescription, health reimbursement arrangements (HRA), some Employee Assistance Programs (EAP), and, in some cases, health care *flexible spending accounts (FSA).

*FSAs may only be offered until the end of the current plan year.

What is the duration of COBRA coverage?
The length of time that an individual can be covered under COBRA depends on the qualifying event. Generally, COBRA coverage is 18 months. The maximum amount of time that an individual can be on COBRA is 36 months (see chart below).

18 Months Coverage – Qualifying Events 36 Months Coverage – Qualifying Events (for spouse and/or dependent children only)
Voluntary/involuntary termination Death of the employee provides 36 months of coverage for surviving spouse or eligible dependent
Reduction of hours Employee’s Medicare entitlement
  Divorce or legal separation
  Dependent child ceases to be a dependent
  Employer bankruptcy

What are my responsibilities as a COBRA participant?
As a COBRA participant, it is your responsibility to:

  • Enroll within 60 days of your notification.
  • Remit your first premium payment within 45 days of your enrollment.
  • Pay your COBRA premium by the first of each month, even if you do not receive a bill.
  • Notify ADP of divorce, legal separation, death of spouse or dependent, any disability or dependent child reaching age limit (varies by health plan).

Why might my COBRA be terminated?
The following are reasons that COBRA coverage would terminate:

  • COBRA premiums are not paid within grace periods allowed
  • COBRA coverage period ends.
  • Qualified beneficiary obtains other health insurance
  • Employer terminates group health coverage for all employees
  • Qualified beneficiary is no longer deemed disabled by the Social Security Administration (applies only to OBRA continuation)
  • Termination for “cause” (i.e., qualified beneficiary submits a false claim)

How will I know if my COBRA coverage is terminated?
ADP will send a letter to you advising that your coverage has been terminated as of the last day you are eligible under COBRA or the last day of the month you made a full and timely premium payment – whichever comes first. ADP cannot exceed COBRA coverage beyond the period for which you are entitled, nor can it reinstate your account should your coverage be terminated due to late receipt of payment.

Can I go to the doctor or pharmacy if I haven’t sent in my payment?
Yes. Simply pay the expense in full, and then seek reimbursement from your insurance carrier once your COBRA premium payment is received and your COBRA coverage is active.

Can I enroll my children or spouse?
Yes, but only if they had coverage under your group health plan immediately before loss of coverage. Newborn children and/or a new spouse can be added and coverage is effective on the date of birth or marriage. ADP must be notified within 30 days of the event.

Can I change my insurance coverage at the time of my Qualifying Event?
Yes. However, you can only change the level of coverage to a lesser one. For example, you may change from family to self. You may change the insurance provider only during open enrollment. In addition, an individual cannot change from a HMO to a PPO or to a high-deductible health plan unless it’s during open enrollment.

Paying Your COBRA Premiums

Why is my premium so expensive?
Your former employer paid a portion of your premium while you were employed, and the payment was split among two or more pay periods in a month. To keep health insurance after loss of group benefits, you are responsible for paying the full amount of your premium plus a 2 percent administration fee. Your COBRA payment is due in full at the first of each month.

How do I pay my premiums?
The fastest and most convenient method of paying your COBRA premium is by using the online payment option. Please refer to your monthly invoice to set up your account and start paying online.

Alternately, you may mail your check with the bill. Your bill is mailed to your home address approximately two weeks prior to the due date. Payment is always due the first day of the month.

What should I do if I don’t receive a billing statement?
Billing statements are sent to your home address each month as a reminder to pay the premium. However, it is your responsibility to notify us of an address change and to remit the full monthly premium payment on the first day of each month, even if you do not receive a billing statement.

Can I pay only for the months I use my benefits?
No. COBRA regulations require there be no lapse in coverage from the date you first became qualified to continue coverage. Your first billing statement will represent continuous coverage retroactive to that date. You’re required to remit a full monthly premium payment for each subsequent month that you’re eligible to receive benefits under COBRA in order to remain covered.

How do I pay my premium online?
Follow the instruction on the back of your invoice to utilize our safe, secure online services. You will be prompted to enter your bank account and routing numbers. It only takes a few minutes to set up your account and start paying online.

Can I pay by credit card?
ADP cannot accept credit card payments at this time. If your credit card company has provided you with checks, you can submit payment via one of these checks for your COBRA coverage.

Using and Maintaining Your COBRA Account

How do I terminate my COBRA (coverage) account?
Your account will terminate automatically if you stop making payments. To request termination of your coverage, please send written notification of cancellation to the address provided on your enrollment form.

If I get married, can I add my spouse?
Yes. Simply notify ADP in writing to the address provided on your enrollment form. However, your spouse will not be a qualified beneficiary. ADP must be notified within 30 days of the event.

If I have a child through birth or adoption, can I add him/her?
Yes. Simply notify ADP in writing to the address provided on your enrollment form. However, your child will not be a qualified beneficiary. ADP must be notified within 30 days of the event.

How do I remove my spouse from COBRA coverage?
Your spouse must notify ADP in writing to the address provided on your enrollment form.

How do I remove my child from COBRA coverage?
You must notify ADP in writing with a signature from either parent. Mail the letter to the address provided on your enrollment form.

Helping You with Your COBRA Account

How long does it take for my COBRA account status to be updated?
It may take anywhere from 72 hours up to two weeks for your insurance company’s system to reflect changes made to your account.

How do I confirm my payment was received?
You may confirm receipt of your payment
online. ADP provides participants with safe, convenient access to personal account data, including premium payment history 24 hours a day, seven days a week. You may also contact ADP by calling the number provided on your monthly invoice.

How do I avoid having my coverage terminated each month?
COBRA coverage is on a month-to-month basis. By paying your premium each month in a timely manner, you minimize the likelihood of coverage being interrupted.

When will I be enrolled?
You should be enrolled within three to five business days after ADP receives your completed enrollment information. Please note: Coverage will not be activated until full payment has been received.

When should I receive my bill?
Generally, participants should receive bills no later than the 18th of the month. However, it is your responsibility to pay your bill in full by the first of each month.

Why does my bill not reflect my last payment?
Payments may post to the account after the next month’s bill has already printed. Therefore, it may not reflect your payment and may show an incorrect amount due on the bill.

What is the fax number?
The general fax number is (502) 267-2233.

What is the mailing address?
For correspondence, please use the address located on your enrollment form.

Where do I send payments?
For payments, please use the address located on your invoice.

How do I get coverage after COBRA?
If your former employer’s plan includes a conversion option, ADP will notify you in writing with information on who to contact for that conversion coverage. Any questions about continuing coverage after your COBRA coverage ends must be directed to the health insurance provider for a possible conversion plan. You will receive a HIPAA certificate upon termination of COBRA coverage. You should save this certificate as other health insurance companies may require you to provide a copy for verification.



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