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COBRA and PEBB Continuation Coverage

Find guidance on PEBB Continuation Coverage related to COVID-19.

General information and requirements

Updated: 3/2021

Applicable to

  • Employees and dependents of the employee considering a temporary extension of PEBB health plan coverage.

Programs

  • COBRA (Consolidated Omnibus Budget Reconciliation Act)
  • PEBB Continuation Coverage

COBRA

COBRA is a temporary extension of PEBB medical and/or dental coverage that may be available if certain circumstances occur that would otherwise end health coverage for the employee and the employee’s qualified beneficiaries under federal rules.

Note: A “qualified beneficiary” can be an employee, spouse, or dependent child.

PEBB Continuation Coverage

PEBB Continuation Coverage provides an alternative, temporary extension of PEBB medical and/or dental coverage for state-registered domestic partners and their children (who are not eligible for COBRA under federal law).  

Who may qualify for COBRA/PEBB Continuation Coverage?

Coverage may be available to:

  • Employees
  • Spouses/State-registered domestic partners
  • Dependent children
  • Retirees

Qualifying events

COBRA/PEBB Continuation Coverage qualifying event

Qualified participants

Maximum length of coverage

Employee terminates employment for reasons other than gross misconduct*

Employee and covered dependents

Up to 18 months

Employee’s hours of employment are reduced to the extent of losing eligibility*

Employee and covered dependents

Up to 18 months

Death of employee or retiree**

Covered dependents

Up to 36 months

Divorce, legal separation or dissolution of a state-registered domestic partnership from employee

Covered dependents

Up to 36 months

Child is no longer eligible

 Covered child

Up to 36 months

Employer group terminates PEBB plan participation

Retiree and their dependents

Up to 18 months
Retiree no longer considered disabled by DRS

Retiree and their dependents

Up to 18 months

*The employee and all qualified dependents may be entitled to receive up to 11 months of additional continuation of coverage, for a total of 29 months, if the Social Security Administration determines the employee or a qualified dependent is disabled. See the PEBB Continuation Coverage Election Notice booklet for details.

**In the event of the death of the employee or retiree, surviving dependents may be eligible to continue coverage under a retiree plan. The dependent should contact PEBB for more information.

Coverage options

Each person who loses coverage:

  • Has an independent right to elect coverage on a self-pay basis
  • Has the option of electing:
    • Medical coverage only,
    • Dental coverage only,
    • Both medical and dental coverage.

Opportunity to change plans

The event that triggers eligibility for COBRA/PEBB Continuation Coverage creates a Special Open Enrollment (SOE).

  • The employee and/or their dependents are given the opportunity to change plans when enrolling.
  • All family members will be enrolled in the same plans
    • Unless the employee and their dependents make separate elections

Enrolling in COBRA/PEBB Continuation Coverage

To elect coverage the employee and/or their dependents must:

  • Return the COBRA Election/Change (Continuation Coverage) form to PEBB
  • No later than 60 days after the mailing date on the PEBB Continuation Coverage Election Notice.

COBRA/PEBB Continuation Coverage procedure

For agencies that key in Pay1

  • When a qualifying event occurs (e.g., termination or retirement), update the insurance system immediately. Untimely keying of terminations can affect employee options and employer financial responsibility. See Addendum 19-1A for more details. Please refer to and follow the PEBB worksheet that best fits the employee’s scenario.

For agencies that don’t key in Pay1

  • If an employee leaves employment because of employment ending, approved Leave without Pay* (LWOP), retirement, or death, complete the Insurance Eligibility System Adjustment form (located under the Miscellaneous heading on the forms page of the Perspay website) listing each separated employee and the effective date of the change. Submit to PEBB Outreach and Training through FUZE.

Note: PEBB will send the Continuation Coverage Election Notice within 14 business days of the employee’s termination in the insurance system.

Forms

Resources

 WAC References

  • WAC 182-12-146 - When is an enrollee eligible to continue PEBB coverage under COBRA?
  • WAC 182-12-260 - Who are eligible dependents?
  • WAC 182-12-265 -  What options for continuing health plan enrollment are available to widows, widowers and dependent children if the employee or retiree dies?
  • WAC 182-12-270 - What options for continuation coverage are available to dependents who cease to meet the eligibility criteria as described in WAC 182-12-260?