We've provided some tips on what to do when an employee's dependent turns 26 and is eligible for COBRA coverage below.
How should we provide notification to an employee when his or her dependent is turning 26, thereby terminating dependent healthcare coverage and triggering COBRA coverage?
Employers are not required to have a unique COBRA notification letter for dependents who lose health care coverage due to the age 26 rule. Under the age 26 rule, a dependent child will qualify for COBRA benefits if he or she loses coverage under a parent's employer-sponsored insurance because the dependent child reached age 26 and is no longer eligible for coverage under the plan as a dependent child. Employers must give such individuals who qualify for COBRA coverage a 60-day opportunity to enroll and may use the standard COBRA notification forms for the notice.
The COBRA Model Election Notice from the U.S. Department of Labor provides all information necessary for a qualified beneficiary who is receiving the notice. The notice states that the dependent will lose coverage under the plan on a specific date (which the employer enters on the notice). A checkbox section allows the employer to choose "Loss of dependent child status" as the reason for election.
As a courtesy, an employer may draft a memo/letter to the employee indicating that coverage for his or her dependent [name of the dependent] will end on [provide a specific date] and COBRA information will be forthcoming. The employer may also indicate if the dependent's loss of coverage will result in any cost changes for the employee.