COBRA continuation coverage is managed by the employer or their COBRA administrator and is separate from ICHRA and QSEHRA benefits administered through Take Command.
What happens to HRA benefits when employment ends?
In most cases, an employee's eligibility for employer-sponsored HRA benefits ends when employment ends.
This includes:
Individual Coverage HRA (ICHRA)
Qualified Small Employer HRA (QSEHRA)
Termination of employment generally ends eligibility for future HRA reimbursements unless otherwise permitted by the employer's plan documents.
What is COBRA?
COBRA (Consolidated Omnibus Budget Reconciliation Act) is a federal law that may allow employees and eligible dependents to continue certain employer-sponsored group health coverage after a qualifying event, such as termination of employment.
COBRA is separate from Take Command's HRA administration services.
Does Take Command administer COBRA?
No.
Take Command does not:
Administer COBRA benefits
Send COBRA election notices
Collect COBRA premiums
Manage COBRA enrollment
Coordinate COBRA continuation coverage
Employers or their COBRA administrators are responsible for all COBRA-related activities.
Who is responsible for COBRA administration?
Employer responsibilities
Employers are responsible for:
Determining COBRA eligibility
Providing required COBRA notices
Managing enrollment deadlines
Collecting COBRA premiums or coordinating with a COBRA administrator
Administering continuation coverage when applicable
Employee responsibilities
Employees are responsible for:
Reviewing COBRA election materials
Deciding whether to elect COBRA coverage
Paying COBRA premiums when enrolled
Managing transitions to new health coverage
Following COBRA enrollment deadlines
Can I use COBRA and an ICHRA at the same time?
Generally, no.
ICHRA eligibility requires qualifying individual health insurance coverage.
Traditional COBRA coverage is continuation of an employer-sponsored group health plan and generally does not satisfy ICHRA eligibility requirements.
Employees enrolled in COBRA should review their specific plan eligibility requirements before seeking reimbursement.
Can I use COBRA and a QSEHRA at the same time?
Possibly.
COBRA coverage generally qualifies as Minimum Essential Coverage (MEC), which may satisfy QSEHRA coverage requirements.
However, eligibility and reimbursement rules depend on the employer's plan design and applicable regulations.
What should employees do after termination?
After employment ends:
Review any COBRA election materials received from the employer.
Evaluate available health coverage options.
Decide whether to elect COBRA coverage or obtain other coverage.
Submit any eligible HRA claims before applicable deadlines.
Retain documentation related to health coverage and reimbursements.
Act promptly, as coverage election and claims deadlines may apply.
Can I still submit HRA claims after termination?
Possibly.
Whether claims may be submitted after termination depends on:
The employer's HRA plan rules
The date services were incurred
Applicable claim submission deadlines
Eligibility requirements established by the employer
Termination of employment does not automatically mean every claim becomes ineligible, but plan rules continue to apply.
What if I purchased coverage directly from an insurance carrier?
If you purchased health insurance directly from a carrier or through the Marketplace:
Contact the carrier regarding continuation options.
Review available enrollment opportunities.
Understand any deadlines that may apply.
Confirm how your coverage will continue after employment ends.
Insurance carriers can explain available options and enrollment requirements.
What does not happen automatically after termination?
The following do not occur automatically through Take Command:
COBRA enrollment
COBRA premium collection
COBRA administration
COBRA notices
Continuation of HRA eligibility
Communication with COBRA administrators
Employers remain responsible for COBRA administration and related communications.
Key takeaway
COBRA continuation coverage is administered by the employer or their COBRA administrator and is separate from Take Command's HRA platform. After employment ends, employees should review COBRA election materials, understand how termination affects HRA eligibility, and submit any eligible claims within applicable deadlines.ately