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Consolidated Omnibus Budget Reconciliation Act (COBRA)

​The Consolidated Omnibus Budget Reconciliation Act (COBRA) of 1985 (enacted July 1, 1986), requires that employers with 20 or more employees, and maintain group benefit plans (including health, dental, vision, and medical reimbursement account), offer continuation of benefit coverage for a specific period of time to covered employees, spouses, domestic partners,* and dependent children who lose group coverage due to a qualifying event.

As a state employee enrolled in state-sponsored benefits, you must be aware of your COBRA rights in the event that you lose coverage due to a qualifying event. You also have the responsibility to report certain life events to your department's personnel office to ensure you and your qualified dependents maintain COBRA eligibility.

*State of California Legislation, not federal law.

Initial General COBRA Notice

Your department's personnel offices will provide the initial general COBRA notice to individuals covered under state-sponsored plans describing their COBRA rights. Your department's personnel offices must provide this notice to covered individuals within the first 90 days of coverage. The notice contains the information that you need to know to protect your COBRA rights while you are covered under the plans. This includes the name of the plan, a general description of the COBRA coverage provided under the plan, HR contact information, and an explanation of any notices you must give your department's personnel office to protect your COBRA rights.

Qualified Beneficiary

A qualified beneficiary is an individual that is eligible to continue group coverage because of a qualifying event. The individual must have been covered under the plan before the qualifying event date. If the individual was not covered, he or she is not eligible for COBRA.

A child enrolled in group coverage when ordered by a National Medical Support Notice (NMSN) or Qualified Medical Child Support Order (QMCSO) is deemed a qualified beneficiary under COBRA law, regardless of his/her status as a dependent of the covered employee. Please note COBRA will only be offered to dependents considered eligible based on the Public Employee Medical and Hospital Care Act (PEMCHA) law.

Qualifying Events

Group coverage may be continued under COBRA for up to 18 months if you lose coverage based on one of the following qualifying events:

  • Voluntary or involuntary termination of employment, other than for gross misconduct;
  • Reduction of hours, including:
    • Reduction of time base to less than half-time
    • Strikes
    • Layoffs
    • Leave of absence (Medical Reimbursement Accounts only. Please see Medical Reimbursement Accounts for more information)
    • Military call-up (Some exceptions apply, please check with your department's personnel office)
    • Permanent-intermittent employee (who loses coverage based on a non-qualifying control period)

While you are still employed, group coverage for your dependents can continue under COBRA for up to 36 months if the loss of coverage is based on one of the following qualifying events:

  • Divorce or termination of domestic partnership
  • Legal separation
  • Death of employee (unless dependent qualifies for continued survivor coverage)

Dependent child ceases to be a dependent (e.g. child turns 26) 

 

​Qualifying Event​Length of Eligibility
​Voluntary or Involuntary Termination of Employment​18 months
​Reduction of Hours to Less than Half-Time​18 months
​Military Call-Up​24 months
​Divorce, Termination of Domestic Partnership, or Legal Separation​36 months
​Child Ceases to be a Dependent (e.g., child turns age 26)​36 months
​Death of Employee​36 months

Extensions to the 18-month Period

AB 1401 - Extension of the Minimum COBRA Coverage Period (Health Only)

Under certain conditions, California law permits an extension of COBRA coverage for an enrollee, up to 36 months from the date coverage began. This extension is managed by the health plan carrier, and you must inquire with the health plan carrier administering the COBRA coverage.

Secondary COBRA Event occurs during the 18-Month Period (Dependents)

Before the end of the original 18 months of COBRA coverage, you may extend COBRA coverage for eligible dependents to 36 months from the original date of loss of coverage if one of the following events occurs:

  • Divorce or termination of domestic partnership
  • Legal separation
  • Death of employee
  • Dependent child ceases to be a dependent (e.g. child turns 26)

It is the qualified beneficiary's responsibility to notify the plan carrier in writing within 60 days of a second COBRA qualifying event and within the original 18-month COBRA timeline.

Under no circumstances will continuation of coverage last beyond 36 months from the original date of loss of coverage.

Social Security Disability Extension to the 18-Month Period

The 18 months of COBRA coverage can be extended for an additional 11 months of coverage, to a maximum of 29 months for all qualified beneficiaries if the Social Security Administration determines a qualified beneficiary was disabled according to Title II or XVI of the Social Security Act at the time of the qualifying event or any time during the first 60 days of COBRA coverage. This extended period allows disabled persons continued coverage for the period of time that it normally takes to become eligible for Medicare. Premiums for this coverage beyond the initial 18 months will be calculated at 150 percent of the State's group coverage premium rate and will continue to be paid monthly directly to the plan carrier or its designee.

It is the qualified beneficiary's responsibility to obtain this disability determination from the Social Security Administration and provide a copy of the determination to the appropriate plan within 60 days after the date of determination and before the original 18-month COBRA eligibility period expires. It is also the qualified beneficiaries' responsibility to notify the plan carrier within 30 days if a final determination has been made that they are no longer disabled.

COBRA Election

Once a COBRA qualifying event occurs or is reported to your department's personnel office, they will send the qualified beneficiary(ies) a COBRA election notice and form. The COBRA Notice informs the qualified beneficiary of their rights under COBRA law, and the form allows the qualified beneficiary to elect COBRA coverage to continue enrollment in benefits. Qualified beneficiaries have 60 calendar days from the date of loss of coverage or from the date of receiving the COBRA Election Notice to elect COBRA coverage, whichever date is later. If a qualified beneficiary does not enroll during this window, they forfeit their right to COBRA coverage.

As of April 28, 2020, there is an extension that allows employees longer than 60 days to elect COBRA coverage; however, please note there is no coverage during the election period. All retroactive premiums will be required to be paid. This extension will remain in place until further notice. This extension will remain in place until further notice.

Premium Payments

If a qualified beneficiary elects COBRA coverage, they will be responsible for 100 percent of the total premium, plus a 2 percent administration fee, which they will pay monthly to the plan carrier or its designee. The plan carrier or its designee is not required to send a monthly bill. The department does not pay a share of the COBRA premium.

Once a qualified beneficiary elects COBRA coverage, they have 45 calendar days from the date of election to pay all retroactive premiums to the plan or its designee. The retroactive premium payment is the premium to cover the period from the date of loss of coverage to the date of election. All claims occurring during the months of retroactivity are held pending the plan receiving the premium payment.

Once the enrollee pays the retroactive premium, future monthly premiums are due by the first of each following month. While due on the first, the enrollee has a maximum thirty-day grace period following the due date in which to make these premium payments. All claims occurring during the month are held until the plan carrier or its designee receives the premium payment. If the applicable payment is not made within the grace period, the plan will cancel coverage back to the end of the prior month in which they had received a premium payment. Once COBRA coverage is cancelled due to nonpayment of COBRA premiums the enrollee will not be reinstated.

For information on where to send payments, please see the “Carrier Contact Information" below.

As of April 28, 2020, there is an extension that allows employees a longer period of time to pay COBRA premiums; however, please note there is no coverage during a period of non-payment. All retroactive premiums will be required to be paid. This extension will remain in place until further notice.  

Health Insurance Premium Payment (HIPP) Program

For Persons Eligible for Medi-Cal

The Health Insurance Premium Payment (HIPP) Program may pay COBRA premiums in certain cases for persons eligible for Medi-Cal. You may inquire about this program by emailing the Department of Health Care Services at: HIPP@dhcs.ca.gov.

For Persons Disabled by HIV/AIDS

Under the Comprehensive AIDS Resources Emergency (CARE) Act of 1990, the Health Insurance Premium Payment (HIPP) Program may pay COBRA premiums for persons unable to work because of a disability due to HIV/AIDS. You may inquire about this program by emailing the Department of Health Care Services at: HIPP@dhcs.ca.gov.

Termination of Coverage

COBRA coverage remains in effect for the specified time or until one of the following events terminates the coverage:

  • Employer ceases to provide group plans (Enrollee is eligible to elect COBRA coverage in a different state-sponsored plan, similar to active employees)
  • Enrollee :
    • Fails to pay required premiums in a timely manner to the carrier or its designee
    • Becomes covered under another employer's plan
    • Becomes covered under Medicare while enrolled in COBRA
    • Is no longer deemed disabled by Social Security and becomes ineligible for extended continuation; or
    • Voluntarily cancels COBRA coverage

The plan provides all termination of COBRA coverage notices to the enrollee.

COBRA Premiums

Frequently Asked Questions

Please visit our COBRA Frequently Asked Questions

Carrier Contact Information

Delta Dental Plans

For Delta Dental PPO, Delta Dental PPO plus Premier Basic, and  Delta Dental PPO plus Premier Enhanced:

Wolfpack Insurance Services, Inc.
 P.O. Box 833
 Belmont, CA 94002-0833
 Attn: COBRA - State of California
 (800) 296-0192
You may also fax the STD. 692 to (650) 591-4022

Pre-Paid Dental Plans

For DeltaCare USA:

Wolfpack Insurance Services, Inc.
P.O. Box 833
Belmont, CA 94002-0833
Attn: COBRA - State of California
(800) 296-0192
You may also fax the STD. 692 to (650) 591-4022


For MetLife Standard Plan and  MetLife Enhanced Plan:

MetLife*
Attn: COBRA Billing
P.O. Box 13724
Philadelphia, PA 19101
Benefit Questions 1-800-880-1800
Billing Questions (949) 471-2283
*Benefits provided by SafeGuard Health Plans, Inc., a MetLife company.


For Premier Access:

Premier Access
8890 Cal Center Drive
Sacramento, CA 95826
Attn: COBRA UNIT
(888) 534-3466


For Western Dental:

Western Dental
530 South Main Street, 6th Floor
Orange, CA 92868
Attn: COBRA UNIT
(866) 859-7525

Union Trust Dental Plans

For Bargaining Unit 6 - CCPOA/Primary Dental (R06), CCPOA/Western Dental (R06), and CCPOA/Primary Dental (S06, M06, E06, C06):

CCPOA Benefit Trust Fund
2515 Venture Oaks Way, Suite 200
Sacramento, CA 95833
(800) 468-6486

For Bargaining Unit 5 (Dental enrollments only) - CAHP (R05)
CAHP Dental Trust
2030 V Street
Sacramento, CA 95818
(800) 734-2247

Vision Plan

Vision Service Plan
Attn: COBRA UNIT - Mailstop 229
P.O. Box 997100
Sacramento, CA 95899-7100
You may also fax the STD. 700 to (916) 463-9031 Ext.4636
(800) 852-7600

  Updated: 3/11/2020
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