Reminder: COBRA members may be terminated for non-payment when certain conditions are met

Since the Department of Labor and Treasury final ruling has been in place some time now, we are reminding groups and COBRA administrators that they may terminate COBRA members for non-payment (back to March 1, 2020) during the Outbreak Period so long as certain conditions are met. 

UnitedHealthcare has implemented a process allowing customers to retroactively terminate COBRA members back to the last pay through date. Notices sent to members have been updated to advise them of the updated process.

Termination of coverage condition:

  • If a COBRA participant pays the entire premium prior to the end of the expiration of the grace period, their coverage will be activated and eligible claims will be paid.   

Credit eligibility:

  • If payment was made by the employer for the COBRA participant in advance of receiving payment by the participant, the employer can terminate the member and would receive a credit for any months paid on behalf of the participant beyond the member's termination date on their next invoice.
  • If no payment has been made by the employer, the term would be processed with no credit

Refer to the COVID-19 FAQ in the COBRA section, which has been updated with this information.

For questions, please contact your UnitedHealthcare representative.