Carpenters Health and Security Plan

COBRA Coverage 

Under the Consolidated Omnibus Budget Reconciliation Act (COBRA), “qualified beneficiaries” may extend health benefits on a self-pay basis under certain circumstances called “qualifying events.”

Qualified Beneficiaries

A qualified beneficiary means:

  • Any individual who, on the day before a qualifying event, is covered under the plan, either as an employee, or as a dependent of an employee.
  • A child who is born to, adopted by, or placed for adoption with an employee (as opposed to another family member) during COBRA, provided the child is enrolled by submitting an enrollment form and a copy of the birth certificate or adoption papers to the plan administrator within 30 days of birth, adoption, or placement for adoption, and the appropriate self-payments are made. The child will have the same COBRA rights as a dependent who was covered by the plan before the qualifying event that resulted in the loss of coverage.

Other dependents who are newly acquired during a period of COBRA may be enrolled in COBRA by submitting an enrollment form along with the appropriate certificates to the plan administrator within 30 days of becoming a dependent. However, such dependents will not be considered qualified beneficiaries.

Only qualified beneficiaries may extend COBRA when there is a second qualifying event.

An individual ceases to be a qualified beneficiary if COBRA is not timely elected, or when the plan’s obligation to provide COBRA otherwise ends.

18-month Qualifying Events

You and your dependents may elect COBRA for a maximum of 18 months following the date coverage would otherwise end due to one of the following qualifying events:

  • Your termination of employment; or
  • Your layoff or reduction in hours of employment.

If you elect COBRA in lieu of Retiree Coverage but do not make the required monthly contributions for COBRA resulting in a loss of COBRA, you also forfeit your right to enroll in Retiree Coverage.

If Social Security determines that a qualified beneficiary is totally disabled, the disabled individual and all qualified beneficiaries may extend COBRA an additional 11 months beyond the original 18 months, to a maximum of 29 months. In order to qualify for this extension, the qualified beneficiary must notify the plan administrator in writing before the expiration of the initial 18 months of COBRA. A copy of the Social Security determination must be included with the written notice. Thereafter, if there is a final determination by Social Security that the individual is no longer disabled, the qualified beneficiary must notify Carpenters Trusts in writing within 30 days of the determination. For an individual who has extended COBRA beyond the initial 18 months, COBRA will end on the earlier of 29 months from the qualifying event, or the month that begins more than 30 days after the final determination has been made that the disabled individual is no longer disabled.

36-month Qualifying Events

A dependent may elect COBRA for a maximum of 36 months following the date coverage would otherwise end due to one of the following qualifying events:

  • Death of the employee;
  • Divorce or legal separation between the employee and spouse; or
  • The dependent child ceases to meet the plan’s definition of “dependent.”

Second Qualifying Event

An 18-month period of COBRA may be extended to 36 months for the affected qualified beneficiary (spouse or child), if one of the 36-month period qualifying events occurs during the first 18 months of COBRA. In no event will COBRA extend beyond 36 months from the date coverage was first lost due to the initial qualifying event. This extension applies only if the qualified beneficiary notifies the plan administrator in writing within 60 days of the second qualifying event. The notice must identify the qualifying event that occurred. In the absence of such notice, COBRA will terminate.

Medicare Entitlement

If you have an 18-month qualifying event after becoming entitled to Medicare, your dependents may continue COBRA until the later of:

  • 18 months from the date coverage would normally end due to the termination of employment or reduction in hours; or
  • 36 months from the date you become entitled to Medicare.

Notice Requirements

The plan offers COBRA only after it has been notified of a qualifying event. A qualified beneficiary is responsible for notifying the plan administrator of a qualifying event that is a divorce, legal separation, or child losing dependent status. The qualified beneficiary must provide this notice to the plan administrator in writing within 60 days of the later of the date of the qualifying event; the date coverage would be terminated as a result of the qualifying event; or the date this booklet or other notice is provided of the procedure for electing COBRA. The notice must identify the individual who has experienced a qualifying event, the employee’s name, and the qualifying event which occurred. If the plan administrator is not notified during the 60-day period, the qualified beneficiary will lose the right to elect COBRA.

If a child is born to, adopted by, or placed for adoption with you during a period of COBRA, you must notify the plan administrator in writing within 30 days of the birth, adoption or placement for adoption, and provide a copy of the child’s birth certificate or adoption papers. If the plan administrator is not notified, the child will lose the right to receive COBRA.

In order to qualify for a Social Security disability extension, the qualified beneficiary must notify the plan administrator in writing before expiration of the initial 18 months of COBRA. A copy of the Social Security determination must be included with the written notice. Thereafter, if there is a final determination by Social Security that the individual is no longer disabled, the qualified beneficiary must notify the plan administrator in writing within 30 days of the determination.

A qualified beneficiary who first becomes, after the date of the election of COBRA, covered under any other group health plan, must notify the plan administrator in writing of the other coverage.

The plan administrator will notify qualified beneficiaries of loss of coverage due to termination of employment, reduction in work hours, or the employee’s death. However, you are encouraged to inform the plan administrator of any qualifying event to best ensure prompt handling of your COBRA rights.

All notices required under this section should be sent to the Carpenters Trust of Western Washington at the address identified on the back cover of this plan booklet.

Election of COBRA

When the plan administrator is notified of a qualifying event, an election form is mailed to the qualified beneficiaries. The election form must be completed and returned to the plan administrator within 60 days of the later of the termination of coverage, or the date the application was sent. If the election form is not sent to the plan administrator by this date, the qualified beneficiaries will lose the right to elect COBRA.

Each qualified beneficiary has an independent right to elect COBRA. An employee or spouse may elect COBRA on behalf of other qualified beneficiaries in the family. A parent or legal guardian may elect COBRA on behalf of a minor child.

Type of Benefits

Under COBRA, a qualified beneficiary may continue medical, prescription drug, dental, and vision coverage, provided the qualified beneficiary was eligible for such benefits immediately prior to the qualifying event. Life insurance, accidental death and dismemberment benefits, and time loss benefits are not available under COBRA.

Cost and Payment

There is a cost for COBRA. Information regarding the cost will be sent with the election forms. The first payment is due 45 days from the date the election form is sent to the plan administrator. The first payment must cover all months since the date coverage would have otherwise terminated. Thereafter, payments must be made monthly to continue COBRA. All payments must be sent to the plan administrator.

COBRA eligibility will not commence, nor will claims be processed for expenses incurred following the date of the qualifying event, until the appropriate COBRA payments have been made. COBRA terminates if a monthly payment is made later than 30 days from the beginning of the month to be covered. If the initial payment, or any subsequent payment is not made in a timely fashion, COBRA terminates.

Termination of COBRA

COBRA ends on the first of the dates indicated below:

  • The last day of the month the maximum coverage period for the qualifying event has ended (18, 29, or 36 months).
  • The last date for which the self-payment was paid, or when the qualified beneficiary does not make the next payment in full when due. Payments must be made within 30 days of the due date.
  • The last day of the month that begins more than 30 days from the final determination that the qualified beneficiary is no longer disabled as determined by Social Security. This applies only to the 19th through 29th month of disability extended COBRA.
  • The date the Trust no longer provides group health coverage or the date the employee’s employer no longer participates in the plan, unless the employer or its successor does not offer another health plan for any classification of its employees which formerly participated in the Trust.

COBRA is provided subject to eligibility. The plan reserves the right to terminate COBRA retroactively if the qualified beneficiary is determined to be ineligible for coverage.

Last Updated: 11/08/2021