Participant status changes and COBRA reporting

The third-party administrator (TPA) must distinguish between active and separated participants when reporting data to the Centers for Medicare and Medicaid Services (CMS).  It is important that you notify the TPA when an enrolled employee/participant is terminated, separates from service for any reason, or retires.  Additionally, these and other status changes may constitute COBRA qualifying events which must also be reported to the TPA.

To report participant status changes and COBRA qualifying events to the TPA, submit a Participant Status Change Form when a currently enrolled employee/participant:

1.       Is voluntarily or involuntarily terminated;

2.       Separates from service or retires;

3.       Experiences a reduction of hours affecting eligibility; or

4.       Passes away.

Any of the above events may constitute a COBRA qualifying event if the employee/participant stops receiving employer contributions to which they or their qualified beneficiaries would have otherwise been entitled (e.g. ongoing monthly contributions).  To comply with federal COBRA requirements, employers must notify the third-party administrator (TPA) within 30 days when a COBRA qualifying event occurs.  Refer to section six in your online employer handbook for more details.

NOTE:  You DO NOT need to submit a Participant Status Change Form for employees who are becoming new HRA VEBA plan participants due to receipt of contributions at termination, separation from service, or retirement.  Report information for these employees on their Enrollment Forms.