COBRA and college students

[Guest susanyb]

Would like some ideas on how others handle college students that decide in August that they are not going back to school in the fall.

We have employees complete Dependent Eligibility Status Forms in May stating whether or not their college age child is returning to school in the fall.

If they say they are returning we continue their active status. In August they call to say their child has now decided not to return. We term their coverage back to 5-31 but now - technically we have a late notification situation.

Some comments please as to how you handle these situations.

[mroberts]

I would just terminate the student as of the date you were notified that he or she is not going back to college. If you term the dependent retroactively, it opens up a can of worms. It could have been the dependent child's true intentions to go back to school, however, something came up and they just couldn't. Most carriers request student verification twice - once in the fall and once before the spring semester. Therefore, the carrier would continue the student through the summer.

[Guest NBastunas]

The same situation has come up here. An employee came to our office to delete an overage dependent that didn't return to school. There is no change in their election since he had other dependents but there is a loss of eligibility and the employee was interested in continuing benefits through COBRA for their daughter.

Do you consider the failure to return to school the Qualifying Event or do you consider the end of the previous semester/quarter the Qualifying Event? If the latter do you make a COBRA offer to all continuing students at the end of any semester/quarter break?

Can you differentiate the two issues - the loss of eligibility and the Qualifying Event?

[mroberts]

Again, if a student is enrolled full-time in a Winter/Spring semester, he or she should be considered a full-time student through the summer whether or not he or she is attending classes during that time, whether or not he or she is going to be a full-time student in the fall, or whether or not the dependent has any intention of going back to school or not.