CSU COBRA Administrative Guide
8
Revised April 2017
60 days of continuation coverage due to such event, continuation coverage may be provided for up to 29
months, instead of 18 months. This extension does not apply to HCRA enrollment.
A disability extension may be elected independently for each qualified beneficiary (the disabled person or any
family member). To qualify for the additional 11 months of coverage, the carrier must be notified within 60 days
of the date Social Security made the disability determination and before the end of the initial 18-month period. If
Social Security makes a determination of disability prior to the date employment ends or hours are reduced, then
CSU must be notified within 60 days of the date employment ends or hours are reduced. CSU (or the carrier)
must be notified within 30 days if the Social Security disability determination expires.
Individuals who qualify for the disability extension, but who are not part of the family unit that includes the
disabled person, may continue to be charged 102% of the applicable group rate. (This situation might occur, for
example, if there is a divorce or legal separation, or if the disabled person does not elect to continue coverage
for the additional 11-month period.) Individuals who qualify for the disability extension, who are part of the family
unit that includes the disabled person, may be charged up to 150% of the applicable group rate for the 19
th
through the 29
th
month. The cost of coverage during the 19
th
through 29
th
month extension period will be 150%
of the monthly group cost. If a second qualifying event occurs during the disability extension, the 30th through
36th month should be charged at 102%.
3.3 36-Month Coverage
The following events qualify eligible qualified beneficiaries enrolled in the Health, Dental and/or Vision plans for
continued coverage for up to a maximum of 36 months:
1. Death of covered employee/retiree;
2.Divorce or legal separation
1
of a spouse (or dissolution of domestic partnership) from a covered
employee/retiree;
3.Termination of a child's dependent status (e.g., dependent reaches age 26);
4. Covered employee/retiree's entitlement to Medicare (Health Only); or
5.Moving out of the household
1
(Health Only).
1
Federal legislation identifies a "Legal Separation" as a qualifying event, and COBRA coverage must be offered. The "legal separation"
process is handled through judicial channels. For purposes of dental and vision coverage only, employees who separate from their
spouses (or “move out of the household”) without filing for "legal separation" status through the court, and those who file for divorce in
lieu of a "legal separation" are not eligible for COBRA continuation coverage until the divorce (if any) becomes final, and then only if
they are enrolled in the plan on the date of divorce. However, if a spouse is dropped from the Plan in anticipation of divorce, the
spouse will be eligible for COBRA when the divorce becomes final. Although not a legal requirement, CalPERS recognizes “moving
out of the household” as a qualifying event for purposes of continued health coverage. This option is not available for participants in the
CSU dental, vision and HCRA plans.
3.4 Multiple Qualifying Events
If a qualifying event occurs that triggers an 18-month continuation coverage period (i.e., a termination of
employment, for reasons other than gross misconduct, or a reduction in hours) and then a second qualifying
event occurs during that 18 month period, the maximum continuation coverage period will be extended to 36
months from the date of the first qualifying event. This extension applies only to a qualified beneficiary who
became a qualified beneficiary as a result of the first qualifying event and was still covered under the group
health plan when the second qualifying event occurred.