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COBRA is the Consolidated Omnibus Budget Reconciliation Act of 1985. This federal law amended the Internal Revenue Code, ERISA, and the Public Health Services Act to require most employers maintaining group health plans to offer employees, their spouses, and their dependents the opportunity to elect continuation coverage, on a self-pay basis, for 18, 29, or 36 months, depending on the qualifying event. COBRA mandates that qualified beneficiaries be provided with the opportunity to elect to continue their group health plan coverage on a self-pay basis for a prescribed period of time.
The three elements necessary to trigger COBRA eligibility are as follows:
  1. The individual must be a qualified individual or beneficiary, which is based on his/her status on the day before the qualifying event. The three classes of individuals who may be qualified beneficiaries are as follows:
    1. Covered employees under a group health plan
    2. Covered spouses of covered employees
    3. Covered dependent children of covered employees
  2. The individual must experience a COBRA qualifying event
  3. The individual must lose group health plan coverage as a result of that event within a certain period of time

The qualifying COBRA events for employees and dependents are as follows:


  1. Termination of employment (for reasons other than the employee’s gross misconduct)
  2. Reduction in the employee’s hours of employment

Employee’s spouse or dependent child(ren):

  1. Termination of employment (for reasons other than the employee’s gross misconduct)
  2. Reduction in the employee's hours of employment
  3. Death of the employee
  4. Divorce or legal separation from the covered employee
  5. The employee's entitlement to Medicare
  6. The child's ceasing to be a covered dependent child under the terms of the plan

A qualified beneficiary who fails to elect COBRA continuation coverage in connection with a qualifying event ceases to be a qualified beneficiary once the COBRA election period expires.

If you become entitled to elect COBRA continuation coverage when you otherwise would lose group health coverage under a group health plan, you should consider all options you may have to get other health coverage before you make your decision. There may be more affordable or more generous coverage options for you and your family through other group health plan coverage (such as a spouse's plan), the federal Health Insurance Marketplace, or Medicaid.

Under the Health Insurance Portability and Accountability Act (HIPAA), if you or your dependents are losing eligibility for group health coverage, including eligibility for continuation coverage, you may have a right to special enroll (enroll without waiting until the next open season for enrollment) in other group health coverage.

Eligibility for COBRA continuation coverage won't limit your eligibility for Marketplace coverage or for a tax credit. You can apply for Marketplace coverage at or by calling 1.800.318.2596 (TTY 1.855.889.4325).

Once HR receives information that qualifies you for COBRA, a notification letter and election form will automatically be mailed to your home address. Each eligible employee and dependent will receive a letter and election form containing his/her specific election options. You have 60 days from the date contained on the COBRA notification letter to elect to continue your coverage. After you have made your COBRA election, you then have 45 days to make your initial payment. However, your initial payment must be for premiums back to the date coverage was lost in order for your coverage to be reinstated, even if you wait until the last day of the election and/or payment periods. See the My VU Benefits website for more information.

  • For employees, the COBRA period is 18 months.
  • For an employee's family members, the COBRA period is 18 months if the qualifying event is the employee’s termination or reduction in hours of employment or 36 months for all other qualifying events.

Various rules also apply that may result in extending the 18-month coverage continuation period. First, a determination by the Social Security Administration that a qualified beneficiary is disabled may result in 29 months of coverage. Second, an 18-month COBRA period may be extended to 36 months for an employee’s family members if a second qualifying event occurs.

The COBRA period starts on the date of the qualifying event, unless the Plan states that the period starts on the date coverage is lost as a result of the qualifying event. For Vanderbilt employees, both of these situations apply. For example, a non-exempt employee's COBRA period begins to run from the date of the qualifying event whereas an exempt employee’s COBRA period begins when coverage is lost (i.e. 1st day of the month following the qualifying event).

Certain events may occur that have the effect of cutting short the applicable COBRA period. These events include:

  1. The employer's ceasing to provide group health plan coverage to any of its employees
  2. The qualified beneficiary's failing to pay premiums in a timely manner
  3. The qualified beneficiary's first becoming, after the COBRA election, covered under another group health plan that:
    • Does not contain an exclusion or limitation applicable to the qualified beneficiary's preexisting condition
    • Contains such an exclusion or limitation, but such exclusion or limitation does not apply to the individual, because he or she has at least 12 months of creditable coverage pursuant to HIPPA (and has not incurred a 63 day break in coverage)
  4. The qualified beneficiary’s first becoming, after the COBRA election, entitled to Medicare
  5. The loss of Social Security disability status

Once COBRA coverage is elected, qualified beneficiaries must be covered under the plan retroactive to the date coverage was lost. Additionally, COBRA coverage can be retroactively cancelled to the first day of any period for which premiums have not been timely paid.

Employers (or Plans) are not required to provide any additional notice to qualified beneficiaries prior to terminating coverage for failure to timely pay premiums.

A qualified beneficiary who fails to elect continuation coverage within the 60-day election period ceases to be a qualified beneficiary and is no longer eligible to elect COBRA coverage with respect to that particular qualifying event once the election period expires. Once qualified beneficiary status is lost, the statute does not require that it be reinstated.

COBRA permits plan sponsors to charge qualified beneficiaries 100 percent of the cost of the coverage, plus an additional 2 percent. Moreover, in the case of a qualified beneficiary entitled to 29 months of COBRA coverage resulting from disability, the plan sponsor generally can charge 150 percent of the cost of coverage for the additional 11 months. Click here to see current rates. For assistance in determining a specific disability rate of 150%, please contact Benefit Express.

The initial payment must include premiums from the first day of COBRA coverage through the current month in which the initial payment is being made.

For example:

  • Your active coverage ended on 1/31/2016, which qualifies you to continue your coverage through COBRA effective 2/1/2016. A COBRA Notification letter was mailed to you on 2/6/2016, in which you now have 60 days to elect COBRA coverage.
  • Your election form is received on 3/1/2016. You now have 45 days to make your initial payment.
  • On 4/15/2016, the payment required in order for your coverage to be retroactively reinstated back to 2/1/2016 would need to be the total of your February 2016–April 2016 premiums (3 months).

Benefit Express has been authorized by Vanderbilt University to process COBRA election forms, premium billing statements and to receive premium payments. If you have any questions, please contact Benefits Express directly toll free at 1.877.837.5017. Representatives are available from 7:30 am – 6:00 pm CST, Monday through Friday. The option to email or mail is also available. Emails should be sent to All mailings can be sent to Benefits Express, P.O. Box 189, Arlington Heights, IL 60006.

Payments are due by the 1st of each month (for the month in which coverage is intended) in order for benefits to continue.

To voluntarily terminate your COBRA coverage, complete the Request to Terminate Coverage form and return it to Benefit Express, the authorized COBRA Administrator for Vanderbilt. Please contact Benefit Express directly in order to obtain the form. Non-payment of premium is considered voluntary termination of benefits.

Benefit Express
1700 E. Golf Road, Suite 1000
Schaumburg, IL 60173

Phone: (877) 837-5017
Fax: (253) 793-3766

You may contact Benefit Express to request your account balance or payment coupons. To ensure your coupons are mailed to the proper location, please notify Benefit Express immediately of any mailing address changes. You will not be sent regular premium notices. It is your responsibility to pay your premiums on or before the date due. Otherwise, we may terminate your participation in the plan.

Benefit Express
1700 E. Golf Road, Suite 1000
Schaumburg, IL 60173

Phone: (877) 837-5017
Fax: (253) 793-3766

No. It is the COBRA participant's responsibility to ensure that payments are made by the 1st of each month. We are not required to contact participants to see why their accounts are delinquent, or ask if coverage is still needed prior to terminating coverage for non-payment.

The group's health plan provides covered employees and their families with certain notices explaining their COBRA rights. Your COBRA rights are described in the Summary Plan Description (SPD). COBRA continuation coverage laws are administered by several agencies. The Departments of Labor and Treasury have jurisdiction over private-sector group health plans. The Department of Health and Human Services administers the continuation coverage law as it applies to state and local governmental health plans.

The Labor Department's interpretive responsibility for COBRA is limited to the disclosure and notification requirements of COBRA. If you need further information on your rights under a private-sector plan, or about ERISA generally, contact the Employee Benefits Security Administration (EBSA) electronically at or call toll free 1.866.444.3272.

To elect benefits as a rehire, you will need to end your COBRA coverage. Contact Benefit Express at or 877-837-5017 and tell them you no longer need COBRA coverage because you have been rehired at VU. Be sure to provide Benefit Express with your rehire date. This will ensure that you do not have a lapse in coverage. Once the system updates are complete, you will be able to enroll for benefits.