Extending COBRA Coverage Due to Disability
Use
The COBRA regulations provide for an extension of COBRA coverage by 11 months if Social Security Administration determines that a qualified beneficiary is disabled before the end of the first 60 days of COBRA coverage. This extension only applies for the qualifying events Termination of employment and Reduction in working hours. Coverage is extended for all beneficiaries within a family covered under COBRA, and not just the disabled person.
According to the COBRA regulations, an employee's absence from work due to disability is a qualifying event of the type Reduction in working hours or Termination of employment, but not a valid type of event in it’s own right. In these cases, the SAP System automatically extends regular COBRA coverage by exactly 11 months.
This procedure describes how to do the following:
Coverage is only automatically extended if a person's disability was registered prior to the relevant COBRA event being identified in COBRA Event Collection and processed in COBRA Letter Generation. Otherwise, you need to extend coverage manually.
Just as the disability extension applies to all beneficiaries within a family covered under COBRA, so can the extended coverage be terminated for all beneficiaries if the disabled person subsequently loses his/her disabled status.
Procedure
Maintaining Master Data for Disabled Employees/Dependents
In HR Master Data, create a new Additional Personal Data record (infotype 0077) for the employee or a new Family/Related Person record (infotype 0021) for the dependent with the relevant disability information.
Manually Extending Coverage Due to Disability
In HR Master Data, extend the validity of the relevant COBRA-Qualified Beneficiary infotype (0211) and the relevant COBRA plan records by 11 months.
Terminating Extended Coverage Due to Loss of Disabled Status
Terminate participation in the
COBRA Participation tool.
The COBRA regulations state that participation can only be terminated in the month that is more than 30 days after a final determination that a qualified beneficiary is no longer disabled.