I have another question sort of on this topic and haven't been able to determine the answer...
We want to extend COBRA coverage (not pay any of the premiums) to a former employee's spouse who was incorrectly told she would have 36 months of COBRA but is only qualified for 18 under our self funded plan. If COBRA ends at 18 months she will have a gap of 13 months until age 65 Medicare qualification. Our vendor has stated we can authorize an exception to extend COBRA coverage, but they do not state what if any consequences this would trigger.
We have already determined stop loss will not pay for this participant's claims during the extended period.
We are not paying premiums at any time for this participant. However, claims paid on behalf of the participant would be paid through the self funded plan and company assets.
This former employee may have been HCE as salary exceeded $120k annually for a couple of years.
I would appreciate any thoughts.
Thank you,