COBRA participants must be allowed the same rights as active employees during annual open enrollment. This includes, but is not limited to, changing between health plans offered at that time or adding dependents.

You must notify them of their options at annual open enrollment, similar to what you do for your active employees.

If you offer both an HMO plan and a Point of Service (or freedom of choice) plan to your active employees (through Dean Health Plan or another carrier), you are required to offer the COBRA participant the opportunity to change over to the freedom of choice plan at the time they move out of the service area.

If you do not offer any options other than an HMO plan, the COBRA participant has the option of purchasing any individual market policy offered in the participant’s new location, either through the Health Insurance Marketplace or by purchasing one directly from an area insurer. Have the participant call our Customer Care Center directly for more information.

No. The second qualifying event must be a “36-month event” such as death of covered employee, divorce from covered employee, etc., in order for the time to be extended to 36 months. Two “18-month events” do not add up to a 36 month event, so the maximum time allowed would be 18 months.

Yes. And a former employee cannot decline COBRA for other qualified beneficiaries (i.e. family members).

Because of this rule, a very cautious approach to offering COBRA is to send out two COBRA election notices: one addressed to the employee and family and one addressed to the spouse and family.

To qualify for the disability extension, the individual must have been disabled during the first 60 days of COBRA coverage and have been determined by the Social Security to be disabled under its definition.

Written notice from the Social Security Administration confirming the disabled determination must be provided to Dean Health Plan within 60 days of the date of the determination for the extension to be considered.

The extension includes all members covered prior to the extension, including spouse and dependents.


An individual may elect COBRA regardless of whether he or she is covered by another group health plan or is entitled to Medicare. COBRA must be offered and cannot be discontinued because of other coverage or Medicare if the individual was enrolled in the other coverage or Medicare before electing COBRA.

If the individual enrolls in another plan or Medicare after electing COBRA, COBRA can be discontinued in that situation.

Medicare will always be primary for an individual on COBRA because he or she is no longer actively at work, and Dean Health Plan will be the secondary payer of claims. This means that a Medicare carve-out (reduced) rate will be charged rather than the full active employee rate.

If you know the individual has Medicare at the time of enrollment on COBRA, make sure his or her Medicare numbers are submitted to us so claims are paid properly and premium is charged accordingly.

COBRA/Continuation is not available to employees if the employer terminates its group coverage.

However, the employees can call the Customer Care Center at 800-279-1301 to get information about individual policies that Dean Health Plan offers.