The 60-day election (EP) period for individuals to notify HMAA of a COBRA qualifying event (QE) may be extended in certain circumstances as described in the following examples. COBRA qualifying events (QE) include divorce or legal separation causing the spouse to lose eligibility; a child losing eligible dependent status (e.g., upon reaching age 26); or determination of a disability that extends the maximum coverage period from 18 to 29 months.

  • Example 1: On March 30, 2020, Nick and his spouse, Melanie, divorce while covered under Nick’s HMAA plan. What is the deadline for Nick or Melanie to notify HMAA of the COBRA qualifying event and provide Melanie the opportunity to elect COBRA coverage? Because Nick and Melanie’s divorce triggered a COBRA qualifying event for Melanie, the Outbreak Period is disregarded. Nick or Melanie have 60 days from the one-year extension date that the timeline would have started (March 30, 2021), in this case until the deadline (May 29, 2021), to inform HMAA of the COBRA qualifying event.
  • Example 2: On February 1, 2020, Ann’s child, Billie, reached age 26 while covered under Ann’s HMAA plan and is therefore no longer an eligible dependent. What is the deadline for Ann or Billie to notify HMAA of the COBRA qualifying event, which would provide Billie the opportunity to elect COBRA coverage? Because Billie’s loss of eligible dependent status triggered a COBRA qualifying event, the Outbreak Period is disregarded. Billie has 31 days* from the end of the Outbreak Period (February 28, 2021), in this case until the deadline (March 31, 2021), to inform HMAA of the COBRA qualifying event. *Timeframe calculation: 60 days (Election Period) – 29 days (utilized prior to outbreak period) = 31 days (EP remaining).
  • Example 3: On February 28, 2020, Matt received a determination of disability from the U.S. Social Security Administration (SSA) qualifying Matt for a disability extension of the maximum COBRA coverage period from 18 to 29 months. Matt was previously covered under his employer-sponsored HMAA plan; however, he has been a COBRA-qualified beneficiary since December 2019 after suffering a stroke. What is the deadline for Matt to inform HMAA of his SSA determination of disability affording him the right to extension of COBRA coverage? Because Matt’s determination of disability triggered a COBRA qualifying event affording him extension of coverage, the Outbreak Period is disregarded. Matt has 58 days* from the end of the Outbreak Period (February 28, 2021), in this case until the deadline (April 27, 2021), to inform HMAA of the COBRA qualifying event extending his coverage. *Timeframe calculation: 60 days (Election Period) – 2 days (utilized prior to outbreak period) = 58 days (EP remaining).