When does coverage end for a dependent child who is a full time student?

[Mary C]

Our plan currently states that coverage ends the end of the month in which a dependent child over the age of 19, but under the age of 23, ceases to be a full time student. We are thinking of amending the plan to provide coverage until the end of the year in which the child ceases to be a full time student and are wondering what other employers/plans do.

[QDROphile]

Other employers might consider the tax consequences of providing benefits to persons who may not be dependents of the employee and the related administrative issues. Part of that consideration would be a close look at section 152©(3)(A) and the requirement that child is not a qualifying child in the YEAR the child attains age 19 unless a student and a student is not a qualifying child in the YEAR that the student attains age 24. The child might continue to be a dependent by meeting the requirements of a qualifying relative.

[oriecat]

Ours is also end of the month.

[Guest georgia]

ditto - end of month

[jsb]

End of the month, 14K primary lives, governmental plan.

[Kirk Maldonado]

What do you do if the student decides not to return to school (following the completion of the current semester) and you don't find that out until the beginning of the new semester? For example, assume that the student finished the prior semester that ended in May, but decided not to return to school the following September.

Consistent with the terms of the plan, do you terminate the coverage retroactively to the last day of the month in which the prior semester ended (which would be May)?

But if you do that, then aren't you automatically late in giving notice to the student of his or her (1) right to elect COBRA and (2) Creditable Coverage under HIPAA?

[Guest georgia]

Current enrollment includes 22K fulltime students. Fulltime student status can be approved for up to a 12-month period based on documentation from an accredited school’s registrar. In Kirk’s scenario our plan would terminate the student coverage prospectively on the last day of the month in which the plan is notified the student was no longer attending school. COBRA notice is sent only upon request and according to COBRA timely notification requirements. Creditable Coverage notices are issued according to HIPAA regs.

[jsb]

Kirk, in our plan (self-administered COBRA) we would look at the intent of the student. If the intent was to enroll, as evidenced by paying fees or similar, we would treat the student as withdrawing from school and everything is prospective. We work to reasonably establish intent. Otherwise, it is treated as a late notification (for COBRA purposes, the onus is on the participant to report loss-of-eligibility events within 60 days), coverage it terminated retroactively, and no COBRA notice or coverage is required.

[Kirk Maldonado]

Thanks for the feedback. I always wondered what clients actually do in those circumstances.

[Sandra Pearce]

We have this provision in our Plan:

If a full-time student subsequently drops below the minimum number of credit hours during a semester, coverage will continue until the beginning of the next school semester. A Dependent enrolled full-time in school will be covered until the beginning of the said next semester (i.e., covered through summer break), unless graduation occurs.

[Guest Jet352]

Suppose the plan only requires student verification once per year (begining of fall semester) but you hear suggestions/comments by the parent that the student has decided to "take a break" after the fall semester and is planning to return the next fall. (of course no payments or enrollment have been made). However, parent has not officially reported this change of status because they do not want to have to pay COBRA rates.

What would be your proceedure for verifying that the student is still a qualified dependent under the plan?

[Guest georgia]

Jet352 - we reserve the right to require re-validation of dependent eligibility at any time. in your scenario a letter would go to the employee requiring renewal of documentation from the registrars office regarding fulltime attendance. if the dependent proves to be ineligible, coverage is terminated the end of the month in which the Plan makes that determination.