BOARD POLICY 4275
COBRA Health Care Continuation
A. The Consolidated Omnibus Budget Reconciliation Act as amended in 1989 (P.L. 101-2391)
requires that the Ironton City Board of Education allow certain persons, deemed “qualified
beneficiaries”, who would otherwise lose their group health coverage due to certain “qualifying
events” to continue that coverage for a certain period of time at the group rate.
B. A “qualifying beneficiary” can be:
1. A “covered employee”: a current or formal employee (including self-employed persons,
independent contractors, and other non-traditional employees) covered under a group
health plan;
2. A spouse of a covered employee;
3. A dependent child of a covered employee;
C. A “qualifying event” for a covered employee can include:
1. Termination of employment for other than gross misconduct;
2. Reduction in hours of employment;
3. Filing of a bankruptcy proceeding (retirees and certain dependents only).
D. A “qualifying event” for a spouse or dependent child can include:
1. A covered employee’s termination of employment (other than for gross misconduct) or reduction in
hours of employment;
2. A covered employee’s death;
3. A spouse’s divorce or legal separation from a covered employee;
4. A covered employee’s entitlement to Medicare;
5. A dependent child’s loss of dependent status under the plan.
E. The plan administrator shall notify all covered employees and their spouses, if any, of their rights under
COBRA. Once plan coverage begins for an individual, that individual and his/her spouse, if any, must
be notified of their rights.
F. If a qualified event occurs, further notice will be issued. Depending on the event, either the Treasurer of
the Board (in cases of termination or reduction in hours of employment, death, or Medicare entitlement)
or the qualified beneficiary (in cases of certain disabilities, divorce, legal separation or loss of dependant
child status) must notify the plan administrator. The plan administrator will then notify the qualified
beneficiaries of their right to elect continuation coverage.
G. Qualified beneficiaries will be given a period of time called the “election period” within which to elect
continuation coverage. This period lasts for at least sixty (60) days. The plan will permit payment for
continuation coverage for the period preceding the election to be made within forty-five (45) days of
the date of election. Premium payment may not be required before the day that is forty-five (45) days
of the date of election.
H. Once coverage is elected; qualified beneficiaries will be required to pay a premium for the continuation
coverage. This premium charged will be established by the Board and may be set up to 102% (or 150%
for additional disability coverage) of the cost of coverage to the plan for similarly situated individuals.
I. Continuation coverage will last up to eighteen (18) months for termination or reduction in hours of
employment (29 months for certain disabled qualified beneficiaries) or 36 months for other events,
depending on the qualifying event. The Board may extend continuation coverage for longer periods
upon adoption of a resolution.