Run: COBRA Continuation Coverage Policy

This policy establishes the Company's procedures for administering COBRA continuation coverage after a qualifying event. It is intended to ensure timely notices, accurate election processing, proper premium collection, and compliant termination of coverage in accordance with **COBRA, 29 U.S.C. §§ 1161–1169**, and related ERISA requirements.

This policy applies to all U.S. employees, former employees, spouses, dependent children, and other qualified beneficiaries who are enrolled in a Company-sponsored group health plan that is subject to COBRA. It also applies to HR, benefits administration, payroll, and any third-party COBRA administrator acting on the Company's behalf. **California employees:** If state continuation coverage or mini-COBRA rules provide greater rights for fully insured plans, those rules will be applied as required by law. This policy does not create coverage beyond what is required by the applicable plan documents and law.

For purposes of this policy, the following terms apply: - **Qualified beneficiary**: An individual entitled to elect COBRA continuation coverage. - **Qualifying event**: An event that results in loss of group health plan coverage and triggers COBRA rights. - **Election notice**: The written notice describing COBRA rights, election deadlines, premium amounts, and payment instructions. - **Election period**: The time allowed to elect continuation coverage after the election notice is provided. - **Grace period**: The period after a premium due date during which coverage will not terminate for nonpayment, if applicable under COBRA rules and the plan. - **Termination of coverage**: The end of continuation coverage due to expiration, nonpayment, Medicare entitlement, or another lawful termination event.

The Company will provide COBRA continuation coverage notices and administer elections in a timely and consistent manner for all eligible qualified beneficiaries. The Company will not interfere with, restrain, or deny COBRA rights, and will not retaliate against any employee or beneficiary for requesting information or exercising continuation coverage rights. The Company will coordinate COBRA administration with the group health plan, carrier, and any third-party administrator to ensure notices, premiums, and coverage changes are handled accurately and in good faith.

1. **Identify qualifying events**: HR or the plan administrator must identify events that may trigger COBRA, including termination of employment, reduction in hours, divorce or legal separation, death, Medicare entitlement, and dependent child loss of eligibility. 2. **Provide required notices**: The Company or its COBRA administrator will provide the general COBRA notice and the election notice within the time required by law after a qualifying event or notice of the event. 3. **Election period**: Qualified beneficiaries will be given the legally required election period to accept or decline continuation coverage. Elections must be submitted in writing or through the approved election method stated in the notice. 4. **Premium payments**: If COBRA is elected, premiums must be paid by the due dates stated in the election notice. The Company may require payment of the initial premium and subsequent monthly premiums in accordance with COBRA rules. 5. **Coverage administration**: If elected and paid for, continuation coverage will be administered retroactively to the loss-of-coverage date, subject to the terms of the plan and applicable law. 6. **Changes during COBRA**: Beneficiaries must promptly report address changes, Medicare entitlement, disability determinations, divorce, death, or dependent status changes that may affect continuation coverage. 7. **Termination of coverage**: Coverage will end when the maximum continuation period expires, premiums are not paid on time, the employer ceases to maintain any group health plan, the beneficiary becomes entitled to Medicare after electing COBRA (where permitted by law), or another lawful termination event occurs.

**HR / Benefits Administration** - Identify qualifying events and coordinate with payroll and the plan administrator. - Ensure notices are issued within required timeframes. - Maintain records of notices, elections, payments, and coverage changes. **Third-Party COBRA Administrator** - Prepare and send election notices, collect elections, track deadlines, and administer premium billing if delegated. - Notify HR of late payments, coverage terminations, and beneficiary status changes. **Payroll** - Provide timely employment status and deduction information needed for COBRA administration. **Qualified Beneficiaries** - Review notices promptly, make elections within the election period, pay premiums on time, and report changes that may affect eligibility. **Policy Holder / Employer** - Maintain compliant procedures, oversee vendor performance, and ensure good-faith administration of continuation coverage.

Failure to follow COBRA procedures may result in legal liability, penalties, plan disputes, and corrective action. Employees or beneficiaries who miss election deadlines or premium due dates may lose continuation rights as permitted by law. Managers and HR personnel who fail to follow this policy may be subject to documented warning, retraining, removal of administrative authority, or other corrective action, up to and including termination of employment, consistent with Company policy and applicable law. This policy will be administered in a manner consistent with ERISA, COBRA, and any applicable state continuation coverage requirements.

This policy will be reviewed at least annually and whenever COBRA, ERISA, IRS guidance, carrier requirements, or state continuation coverage rules change. Revisions must be approved by HR leadership, Benefits, and Legal/Compliance before publication.