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Cobra In SHOP

The Affordable Care Act does not change Consolidated Omnibus Budget Reconciliation Act (COBRA) and related requirements for employers.

FF-SHOPs will NOT notify employees about COBRA or state mini-COBRA coverage. It is the employer's responsibility to notify employees terminated from coverage about their ability to extend health coverage through COBRA.

COBRA enrollees will appear on an employer’s monthly invoice. It is the responsibility of the employer to collect COBRA premiums from terminated employees and to submit these payments as part of the employer’s monthly premium submission.

It is also the responsibility of the employer to terminate a COBRA enrollee for non-payment of premium or when the former employee is no longer eligible to continue coverage.

If an employer chooses to offer dental coverage, that coverage would continue through COBRA, to the extent dental is available based on each state's mini-COBRA laws

Employee requirements for COBRA:

An employee must enroll in COBRA within 60 days of losing SHOP coverage, and the COBRA effective date will be the day after SHOP coverage was terminated.

COBRA enrollees will need to continue their current SHOP plan upon initial enrollment in COBRA, but will be able to change plans during their previous employer’s annual open enrollment period. Because of legal restrictions, FF-SHOPs are not able to administer COBRA for an employer or invoice COBRA enrollees directly.

It may be beneficial for COBRA enrollees and their dependents to seek lower-cost coverage through the Individual Marketplace.


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