COBRA Compliance Checklist
Essential 25-Point Checklist for HR Departments
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Company Information
Company Name:
_________________________
Date:
_________________________
HR Contact:
_________________________
Plan Year:
_________________________
⚠️ Critical Deadlines to Never Miss
14 days
- Election notice after qualifying event ($110/day penalty)
30 days
- Notify plan administrator of qualifying event
60 days
- Employee election period
45 days
- First payment after election
90 days
- General notice for new enrollees
1. COBRA Notice Requirements
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General Notice Process Established
Provided to all new employees and spouses within 90 days of coverage
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Election Notice Template Ready
DOL-compliant template customized with company information (14-day deadline)
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Qualifying Event Notice Process
System to notify plan administrator within 30 days of qualifying events
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SPD Includes COBRA Information
Summary Plan Description contains required COBRA rights information
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Notice Delivery Method Documented
Proof of delivery system (certified mail, electronic with confirmation, etc.)
2. Qualifying Event Management
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Termination Procedures Include COBRA
COBRA process integrated into employee termination checklist
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Hours Reduction Monitoring
System to identify when reduced hours trigger COBRA eligibility
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Dependent Status Changes Tracked
Process for divorce, legal separation, and aging-out dependents
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Death Benefit Procedures
COBRA notification included in employee death benefit procedures
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Medicare Entitlement Tracking
Process to identify when employees become Medicare entitled
3. Premium Calculation & Payment Processing
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Premium Calculation Method Documented
Clear process for calculating 102% of total premium cost
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First Payment Instructions Clear
45-day initial payment deadline clearly communicated
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Monthly Payment Processing System
Due on 1st of month with 30-day grace period tracking
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Non-Payment Termination Process
Procedures for terminating coverage after grace period expires
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Premium Change Notifications
System to notify COBRA participants of premium changes
4. Coverage Duration & Extensions
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18-Month Coverage Tracking
System for tracking standard 18-month coverage period (termination/hours reduction)
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36-Month Coverage Tracking
System for tracking 36-month coverage (divorce, death, dependent status)
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Disability Extension Process (29 months)
Procedures for SSA disability determination and 11-month extension
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Second Qualifying Event Procedures
Process to extend coverage to 36 months upon second qualifying event
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Maximum Coverage End Date Tracking
System to notify participants before coverage expires
5. Recordkeeping & Audit Preparation
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6-Year Document Retention Policy
All COBRA notices, elections, and payments retained for 6 years
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Open Enrollment Rights Documented
COBRA participants included in annual open enrollment communications
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DOL Audit File Organized
Central file with all COBRA procedures, notices, and participant records
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Annual COBRA Compliance Review
Regular review of procedures and updates for regulation changes
📝 Notes & Action Items