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Continuation of Coverage for Benefited Employees (COBRA)

Insurance Hands Over Family

Under a federal law commonly known as COBRA, the City of San Diego is required to offer you, your spouse, and dependent children the opportunity to temporarily continue group health coverage at group rates plus 2% admin fee where coverage under the plan would otherwise be reduced or terminated because of certain life events (known as "qualifying events").

Individuals entitled to COBRA continuation coverage (known as "qualified beneficiaries") are you, your spouse, and dependent children who are covered under the plan at the time of a qualifying event. In addition, a child who is born to you or adopted or placed for adoption with you during the COBRA coverage period is also a qualified beneficiary.

This website is intended to inform you (and your covered dependents, if any) in a summary fashion of your potential future options and obligations under COBRA. Should an actual qualifying event occur, complete the Qualifying Event Form within 30 days of the event (e.g. separation, divorce, etc.).

Employees who terminate employment with the City of San Diego will automatically be mailed a COBRA Coverage Election Notice via US Mail from WageWorks, the City’s COBRA administrator. You will have 60 days to enroll in COBRA coverage and an additional 45 days to pay the associated premiums.

WageWorks

Once you have received your COBRA Election Notice you can create and access your online account at mybenefits.wageworks.com. If you need assistance you can click the Message Center tab or call 1-877-722-2667 from 5 a.m. to 5 p.m. Pacific Time, Monday through Friday (excluding holidays).

Notification of Address Change

To ensure that all covered individuals receive information properly and efficiently, it is important that you keep your address current by logging into the SAP Portal (City employees only) and updating your Personal Profile in SAP Self-Services. If you have already left City employment you may call Personnel at 619-236-6400 to update your contact information.  Failure on your part to do so may result in delayed notifications or a loss of COBRA coverage options.


COBRA Continuation Chart

Qualifying Events That Result in Loss of Coverage Maximum Continuation Period (months)
Employee Spouse Child
Employee’s work hours are reduced and results in loss of coverage 18 18 18
Employee terminates employment for any reason (other than gross misconduct) 18 18 18
Employee becomes entitled to Medicare as a retiree N/A 36 36
Employee or dependent is disabled (as determined by the Social Security Administration) at the time of the qualifying event or becomes disabled within the first 60 days of COBRA continuation that begins as a result of termination or reduction in work hours 29 29 29
Employee dies N/A 36 36
Employee and spouse legally separate or divorce N/A 36 36
Employee becomes entitled to Medicare within 18 months prior to termination of employment or reduction in work hours N/A 36* 36*
Child no longer qualifies as a "dependent child" N/A N/A 36
For medical coverage only, after initial 18-month federal COBRA coverage (caused by termination of employment or reduction in work hours) has been exhausted, an employee and covered dependents are entitled to Cal-COBRA extended coverage. 18 18 18

* 36-month period is counted from the date you become entitled to Medicare

Qualifying Events and Continuation of Coverage

If your employment terminates for any reason other than your gross misconduct or if your hours worked are reduced so that your plan coverage terminates, you, your covered spouse, and dependent children may continue medical coverage under the plan for up to 18 months.

If you should die, become legally separated or divorced, or become entitled to Medicare as a retiree, your covered dependents whose medical coverage under the plan would be reduced or terminated may continue medical coverage under the plan for up to 36 months. Also, your covered children may continue medical coverage for up to 36 months after they no longer qualify as covered dependents under the terms of the plan.

Upon completion of the original 18-month COBRA continuation period you and your covered dependents may extend your medical coverage only for an additional 18-month period under Cal-COBRA. Your insurer will provide you notice of your extension rights prior to your original COBRA ending.

Extension of the 18-month Period of Continuation Coverage

Certain events may extend an 18-month COBRA continuation period applicable to your termination of employment or reduction in hours worked.

Second Qualifying Event: If your dependents experience a second qualifying event within the original 18-month period, they (but not you) may extend the COBRA continuation period for up to an additional 18 months (for a total of up to 36 months from the original qualifying event).

Medicare Eligible: If you (the employee) became entitled to Medicare while employed (even if it was not a qualifying event for your covered dependents because their coverage was not lost or reduced) and then a second qualifying event (such as your termination of employment or reduction in hours of work) happens within 18 months, your dependents may elect COBRA continuation for up to 36 months from the date you became entitled to Medicare.

If you or your Dependent is Disabled: If the Social Security Administration has determined that you or your dependent is disabled on the date of a termination of employment or reduction in work hours or at any time during the first 60 days of COBRA continuation coverage due to such event, each qualified beneficiary (whether or not disabled) may extend COBRA continuation coverage for up to an additional 11 months (for a total of up to 29 months).

To qualify for this disability extension, WageWorks must be notified of the person’s disability status both within 60 days after the Social Security disability determination is issued and before the end of the original 18-month COBRA continuation period. Also, if Social Security determines that the qualified beneficiary is no longer disabled, you are required to notify WageWorks within 30 days after this determination.

Note: If a second qualifying event occurs at any time during this 29-month disability continuation period, then each qualified beneficiary who is a spouse or dependent child (whether or not disabled) may further extend COBRA coverage for seven more months, for a total of up to 36 months from the termination of employment or reduction in hours of employment.  Please see cost section as cost of coverage increases during this period.

Providing Notice that a COBRA Event Has Occurred

Dependents of Active Employees: To qualify for COBRA continuation upon legal separation or divorce under the plan, you or your spouse are required to notify the Flexible Benefits Division within 30 days of the event (e.g. date of divorce or separation).  Your spouse will then be provided with instructions from WageWorks via US Mail for continuing his/her medical coverage.  WageWorks will automatically be notified of the loss of your child’s dependent status (e.g. he/she has reached age 26) and will send instructions to the address on file.

Note: If you are an active employee and have a disabled child who reaches age 26 he/she may be eligible to continue medical coverage through the City of San Diego’s benefits plan.  You will need to provide proof that your child meets the disability requirement to the Flexible Benefits Division by the end of the month in which your child turns age 26.  Acceptable proof includes certification from the HMO carrier (e.g. Kaiser, Cigna, Sharp, etc.) or a letter from the Social Security Administration.

For other Qualifying Events: If your employment ends, your hours are reduced, or you die, the Flexible Benefits Division will notify WageWorks of the qualifying event who will then provide you and/or your covered dependents with instructions for continuing medical coverage.  If you or your dependents become entitled to Medicare while you are on COBRA, you are responsible for notifying WageWorks.

Individuals already on COBRA: Individuals who are currently receiving medical coverage through COBRA continuation are required to notify WageWorks within the 30-day deadline period if a legal separation or divorce occurs that would extend the period of COBRA coverage for your ex-spouse.  If this notification is not completed in a timely manner, then rights to COBRA continuation coverage may be forfeited.

Electing COBRA Continuation Coverage: You and/or your covered dependents must choose to continue coverage within 60 days after the later of the following dates:

  • The date you and/or your covered dependents would lose coverage as a result of the qualifying event
  • The date that WageWorks notifies you and/or your covered dependents of your right to choose to continue coverage as a result of the qualifying event

Cost

Continuing Active or Retiree Coverage: The cost of COBRA coverage is 102% of the full cost of plan coverage.  Please refer to the annual Benefits Information and Costs booklet on the Flexible Benefits website for current year costs and add 2% to calculate the COBRA amount.

Additional Cost Requirements for Continuation of Active Coverage Only: The cost of coverage for the 19th through 29th months of coverage under the disability extension is

  1. 150% of the full cost of coverage for all family members participating in the same coverage option as the disabled individual, and
  2. 102% for any family members participating in a different coverage option than the disabled individual, except as provided below.

If a second qualifying event occurs during the first 18 months of coverage, the 102% rate applies to the full 36 months even if the individual is disabled. However, if a second qualifying event occurs during the otherwise applicable disability extension period (that is, during the 19th through 29th month), then the rate for the 19th through 36th months of the COBRA continuation period is:

  1. the 150% rate for all family members participating in the same coverage option as the disabled individual, and
  2. the 102% rate for any family members in a different coverage option than the disabled individual.

Paying for COBRA Continuation Coverage

Premium Due Date: If you elect COBRA continuation coverage, you must pay the initial premium (including all premiums due but not paid) within 45 days after your election. Thereafter, COBRA premiums must be paid monthly and within 30 days of each due date. If you elect COBRA continuation but then fail to pay the premium due within the initial 45-day grace period, or you fail to pay any subsequent premium within 30 days after the date it is due, your coverage will be terminated retroactively.

Premiums may be submitted in one of three ways:

  1. Your online account, which gives you the option to make one-time payments each month or set up recurring payments (automatic withdraw of funds from your bank account each month).
  2. Using the WageWorks interactive phone system at 1-877-722-2667. Calls are toll-free and you can access the phone system 24 hours a day, seven days a week.
  3. Mailing payments (check or money order, please make it payable to WageWorks) to this address:

WageWorks

P.O. Box 660212

Dallas, TX 75266-0212

Coverage During the Continuation Period

If coverage under the plan is changed for active employees, the same changes will be provided to individuals on COBRA continuation.  Qualified beneficiaries also may change their coverage elections during the annual enrollment periods, if a change in status occurs, or at other times under the plan to the same extent that similarly situated non-COBRA employees or retirees may do so.

When COBRA Continuation Coverage Ends

COBRA continuation of medical coverage for any person will end when the first of the following occurs:

  • The applicable continuation period ends.
  • The initial premium for continued coverage is not paid within 45 days after the date COBRA is elected, or any subsequent premium is not paid within 30 days after it is due.
  • After the date COBRA is elected, the qualified beneficiary first becomes covered (as an employee or otherwise) under another group medical plan not offered by the City of San Diego, and the other plan does not contain an exclusion or limitation affecting the person’s preexisting condition, or the other plan’s preexisting condition limit or exclusion does not apply or is satisfied because of the HIPAA rules.
  • After the date COBRA is elected, the qualified beneficiary first becomes entitled to Medicare. (This does not apply to other qualified beneficiaries who are not entitled to Medicare.)
  • In the case of the extended coverage period due to a disability, there has been a final determination, under the Social Security Act, that the qualified beneficiary is no longer disabled. In such a case, the COBRA coverage ceases on the first day of the month that begins more than 30 days after the final determination is issued, unless a second qualifying event has occurred during the first 18 months.
  • For newborns and children adopted by or placed for adoption with you (the employee) during your COBRA continuation period, the date your COBRA continuation period ends unless a second qualifying event has occurred.
  • The City of San Diego terminates all group medical coverage for all employees and retirees.
  • A qualified beneficiary notifies WageWorks that they wish to cancel COBRA coverage.

When your COBRA coverage terminates, you may be able to convert your coverage to individual, nonplan coverage under the plan’s conversion rights feature. Contact your carrier for further details.  You may also find affordable coverage through the marketplace at Covered California.


Frequently Asked Questions

I’m retiring . . . when will my employee benefits end?

Upon retirement, your health plans will continue through the end of the month of your last day of active employment.  Your last day of active employment is the day before the date entered into SAP Self-Services as your separation date.  For example, if your separation date is Aug. 1, then your last day of being an active employee will be July 31.  In this scenario July 31, will also be your last day of active coverage.

If your separation date is Aug. 2 then your last day of being an active employee is Aug. 1, and your last day of active coverage would be Aug. 31.

How is my insurance continued under COBRA?

The City of San Diego generally has 30 days to notify WageWorks about a qualifying event entitling you to COBRA coverage. Once they are notified, WageWorks has 14 days to send you an Election Notice. Upon receipt, complete the Election Notice, select the type of coverage you desire, sign it and mail before the election deadline.  The postmark must be on or before the election deadline. The election deadline date is marked on your election notice.

You can choose to send your initial payment with your election notice or wait to send your initial payment within 45 days of the date you return your election notice. Regardless of when you send your initial payment, this payment must be retroactive, bringing your account current from the day your COBRA coverage began to the date you are sending your payment. Payment must be received before your coverage will be effective.

You also have the option of making your COBRA election and paying your premium on-line at mybenefits.wageworks.com.

Will I receive a statement each month?

You will receive monthly invoices. However, it is your (the participant’s) responsibility to make payments regardless of whether or not you have received an invoice or payment coupons. Billing and payment information can be obtained by contacting WageWorks.

Can my premium be withdrawn from my bank account?

Yes. WageWorks can accept ACH transactions, checks, money orders, and online payments. They cannot process payments using credit cards or bank drafts.

How do I cancel my COBRA coverage?

You must submit your request in writing to WageWorks, stating you wish to cancel coverage starting on a particular date. In your letter, please include your Social Security number and/or participant identification number.  Alternatively you can send a message on-line at mybenefits.wageworks.com.

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