MICHIGAN CIVIL SERVICE COMMISSION
Employee Benefits Division
General Notice Of COBRA Continuation Coverage Rights Under COBRA
Introduction
You’re getting this notice because you recently gained coverage under the state’s group health,
vision, or dental plan (the Plan). This notice has important information about your right to
COBRA continuation coverage, which is a temporary extension of coverage under the Plan. This
notice explains COBRA continuation coverage, when it may become available to you and
your family, and what you need to do to protect your right to get it. When you become
eligible for COBRA, you may also become eligible for other coverage options that may cost less
than COBRA continuation coverage.
The right to COBRA continuation coverage was created by a federal law, the Consolidated
Omnibus Budget Reconciliation Act of 1985 (COBRA). COBRA continuation coverage can
become available to you and other members of your family when Plan coverage would otherwise
end. For more information about your rights and obligations under the Plan, federal law, Civil
Service Commission regulations, and your collective bargaining agreement, you should review
the Plan’s Summary Plan Description or contact the Plan Administrator.
You may have other options available to you when you lose group health coverage. For
example, you may be eligible to buy an individual plan through the Health Insurance
Marketplace. By enrolling in coverage through the Marketplace, you may qualify for lower costs
on your monthly premiums and lower out-of-pocket costs. Additionally, you may qualify for a
30-day special enrollment period for another group health plan for which you are eligible (such
as a spouse’s plan), even if that plan generally doesn’t accept late enrollees.
What is COBRA continuation coverage?
COBRA continuation coverage is a continuation of Plan coverage when it would otherwise end
because of a life event. This is also called a “qualifying event.” Specific qualifying events are
listed later in this notice. After a qualifying event, COBRA continuation coverage must be
offered to each person who is a “qualified beneficiary.” You, your spouse, and your dependent
children could become qualified beneficiaries if coverage under the Plan is lost because of the
qualifying event. Under the Plan, qualified beneficiaries who elect COBRA continuation
coverage must pay for COBRA continuation coverage.
If you’re an employee, you’ll become a qualified beneficiary if you lose your coverage under the
Plan because of the following qualifying events:
Your hours of employment are reduced, or
Your employment ends for any reason other than your gross misconduct.
If you’re the spouse of an employee, you’ll become a qualified beneficiary if you lose your
coverage under the Plan because of the following qualifying events:
Your spouse dies;
Your spouse’s hours of employment are reduced;
Your spouse’s employment ends for any reason other than his or her gross misconduct;
Your spouse becomes entitled to Medicare benefits (under Part A, Part B, or both); or
You become divorced or legally separated from your spouse.
REV 07/2020
Your dependent children will become qualified beneficiaries if they lose coverage under the Plan
because of the following qualifying events:
The parent-employee dies;
The parent-employee’s hours of employment are reduced;
The parent-employee’s employment ends for any reason other than his or her gross
misconduct;
The parent-employee becomes entitled to Medicare benefits (Part A, Part B, or both);
The parents become divorced or legally separated; or
The child stops being eligible for coverage under the Plan as a “dependent child.”
When is COBRA continuation coverage available?
The Plan will offer COBRA continuation coverage to qualified beneficiaries only after the Plan
Administrator has been notified that a qualifying event has occurred. The employer must notify
the Plan Administrator of the following qualifying events:
The end of employment or reduction of hours of employment;
Death of the employee; or
The employee’s becoming entitled to Medicare benefits (under Part A, Part B, or both).
For all other qualifying events (divorce or legal separation of the employee and spouse or a
dependent child’s losing eligibility for coverage as a dependent child), you must notify the
Plan Administrator within 60 days after the qualifying event occurs. You must provide this
notice to the MI HR Service Center and request an Application for Continuation of
Insurances, form CS-1820.
How is COBRA continuation coverage provided?
Once the Plan Administrator receives notice that a qualifying event has occurred, COBRA
continuation coverage will be offered to each of the qualified beneficiaries. You will be sent an
election notice and an election form upon notification that you have experienced a qualifying
event. If you wish to continue any coverages, complete the election form as soon as possible, but
no later than the due date on the form. Mail it directly to the Michigan Civil Service
Commission, Employee Benefits Division, P.O. Box 30002, Lansing, MI 48909. If you do not
submit your election form within 60 days from the date on the election form, your group
insurances will remain cancelled and you will forfeit your rights for continuation of
coverage under COBRA.
Each qualified beneficiary will have an independent right to elect COBRA continuation
coverage. Covered employees may elect COBRA continuation coverage on behalf of their
spouses, and parents may elect COBRA continuation coverage on behalf of their children. The
qualified beneficiary will be sent monthly invoices requiring payment in advance for any chosen
continued coverage. Continuation coverages will be provided only after the premium payment is
fully and timely made.
If you elect COBRA continuation coverage you will be offered coverage which is the same as
coverage provided under the plan to similarly situated employees or family members.
You may have the opportunity to change your coverages during the Open Enrollment period
while on a leave, layoff, or separated. Your Open Enrollment change will be processed if your
current coverage is paid through September 30 and your COBRA eligibility allows the change.
REV 07/2020
COBRA continuation coverage is a temporary continuation of coverage that generally lasts for
18 months due to employment termination or reduction of hours of work. Certain qualifying
events, or a second qualifying event during the initial period of coverage, may permit a
beneficiary to receive a maximum of 36 months of coverage.
There are also ways in which this 18-month period of COBRA continuation coverage can be
extended:
Disability extension of 18-month period of COBRA continuation coverage
If you or anyone in your family covered under the Plan is determined by the Social Security
Administration (SSA) to be disabled and you notify the Plan Administrator in a timely fashion,
you and your entire family may be entitled to get up to an additional 11 months of COBRA
continuation coverage, for a maximum of 29 months. The disability would have to have started
at some time before the 60th day of COBRA continuation coverage and must last at least until
the end of the 18-month period of COBRA continuation coverage. To qualify for this extension,
you must provide notification to the Employee Benefits Division (EBD) within 60 days after the
SSA issues the determination of disability and before the close of the 18-month coverage period.
If COBRA continuation coverage is extended because of a disability, you must send to the EBD
any SSA determination that the person whose disability resulted in the extension is no longer
disabled within 30 days of receipt from the SSA.
Second qualifying event extension of 18-month period of continuation coverage
If your family experiences another qualifying event during the 18 months of COBRA
continuation coverage, the spouse and dependent children in your family can get up to 18
additional months of COBRA continuation coverage, for a maximum of 36 months, if the Plan is
properly notified about the second qualifying event. This extension may be available to the
spouse and any dependent children getting COBRA continuation coverage if the employee or
former employee dies; becomes entitled to Medicare benefits (under Part A, Part B, or both);
gets divorced or legally separated; or if the dependent child stops being eligible under the Plan as
a dependent child. This extension is only available if the second qualifying event would have
caused the spouse or dependent child to lose coverage under the Plan had the first qualifying
event not occurred.
Are there other coverage options besides COBRA Continuation Coverage?
Yes. Instead of enrolling in COBRA continuation coverage, there may be other coverage options
for you and your family through the Health Insurance Marketplace, Medicare, Medicaid,
Children's Health Insurance Program (CHIP) or other group health plan coverage options
(such as a spouse’s plan) through what is called a “special enrollment period.” Some of
these options may cost less than COBRA continuation coverage. You can learn more about
many of these options at www.healthcare.gov.
REV 07/2020
Can I enroll in Medicare instead of COBRA continuation coverage after my group health
plan coverage ends?
In general, if you don’t enroll in Medicare Part A or B when you are first eligible because you are
still employed, after the Medicare initial enrollment period, you have an 8-month special
enrollment period
1
to sign up for Medicare Part A or B, beginning on the earlier of
The month after your employment ends; or
The month after group health plan coverage based on current employment ends.
If you don’t enroll in Medicare and elect COBRA continuation coverage instead, you may have to
pay a Part B late enrollment penalty and you may have a gap in coverage if you decide you want
Part B later. If you elect COBRA continuation coverage and later enroll in Medicare Part A or B
before the COBRA continuation coverage ends, the Plan may terminate your continuation
coverage. However, if Medicare Part A or B is effective on or before the date of the COBRA
election, COBRA coverage may not be discontinued on account of Medicare entitlement, even if
you enroll in the other part of Medicare after the date of the election of COBRA coverage.
If you are enrolled in both COBRA continuation coverage and Medicare, Medicare will generally
pay first (primary payer) and COBRA continuation coverage will pay second. Certain plans may
pay as if secondary to Medicare, even if you are not enrolled in Medicare.
For more information visit https://www.medicare.gov/medicare-and-you.
If you have questions
Questions concerning your Plan or your COBRA continuation coverage rights should be
addressed to the contact or contacts identified below. For more information about your rights
under the Employee Retirement Income Security Act (ERISA), including COBRA, the Patient
Protection and Affordable Care Act, and other laws affecting group health plans, contact the
nearest Regional or District Office of the U.S. Department of Labor’s Employee Benefits Security
Administration (EBSA) in your area or visit www.dol.gov/ebsa. (Addresses and phone numbers of
Regional and District EBSA Offices are available through EBSA’s website.) For more information
about the Marketplace, visit www.HealthCare.gov.
Keep your Plan informed of address changes
To protect your family’s rights, let the Plan Administrator know about any changes in the
addresses of family members. You should also keep a copy, for your records, of any notices you
send to the Plan Administrator.
Plan contact information
This notice does not fully describe COBRA or the Plans. Questions on the plans or COBRA
continuation coverage rights should be addressed to the contact or contacts identified below. If
you have questions about continuing State group insurances, please contact the MI HR Service
Center* or your union representative. Remember to contact the MI HR Service Center* if your
marital status, your dependent child’s eligibility status, or your mailing address has changed.
MI HR Service Center
P.O. Box 30002, Lansing, MI 48909
877-766-6447
Michigan Relay Center: 711
FAX 517-241-5892
1
https://www.medicare.gov/sign-up-change-plans/how-do-i-get-parts-a-b/part- a-part-b-sign-up-periods. These rules are
different for people with End Stage Renal Disease (ESRD).