COBRA

Many carriers have special handling for COBRA enrollments or modifications, and it’s important that requests to Noyo are properly flagged as relating to COBRA members. It’s best practice to provide all COBRA details whenever a request includes a member enrolled in COBRA.

Each member snapshot should contain a cobra_details block, as shown below. Full details for COBRA submissions can be found in the Member Snapshot API Reference.

"cobra_details": {
	"cobra_enrolled": True,
	"qualifying_event_reason": "termination_of_employment",
	"qualifying_event_date": "2023-11-15",
	"eligibility_start_date": "2023-12-01",
	"eligibility_end_date": "2025-05-31"
}

To ensure a carrier is able to process your COBRA requests correctly, all COBRA enrollments must be sent with cobra_enrolled= true, an eligibility_start_date, and an eligibility_end_date.

Noyo recommends always including the qualifying_event_reason and qualifying_event_date when available, as some carriers may request it.

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Enrolling a member in COBRA coverage

• The cobra_details.eligibility_start_date field should be the first day without regular coverage, as COBRA coverage must be continuous with regular coverage. For example, if a member’s regular coverage ends 11/30, the COBRA coverage would start on 12/1.
• The cobra_details.eligibility_end_date should reflect the final day of the member’s maximum COBRA-eligible period (usually 18 months).
• The enrolled_member.effective_start_date field should reflect the start date prior to COBRA coverage unless otherwise indicated by carrier requirements.
• The enrolled_member.effective_end_date field should be sent as datemax (9999-12-31).
• The enrolled_member.latest_change_effective_date field should reflect the member’s first day of COBRA coverage.

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Terminating a member from COBRA coverage

• The cobra_details.cobra_enrolled field should remain = true.
• The enrolled_member.effective_end_date field should reflect the last day of the member’s COBRA coverage.
• The cobra_details.eligibility_end_date field should be updated if the member is no longer eligible for COBRA.

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Re-enrolling in Active coverage (following a previous enrollment in COBRA)

• Omit the cobra_details element.
• The enrolled_member.effective_start_date field should reflect the start of the new active (non-COBRA) coverage period.
• The enrolled_member.effective_end_date field should be sent as datemax (9999-12-31).

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Other COBRA requirements and notes

• Some carriers may require the COBRA QLE date. Unless otherwise indicated by carrier requirements, this will be the date that the member experienced their COBRA-qualifying event, which may fall prior to their last day of active coverage as an employee. For example, a member may experience a COBRA-qualifying event the day they end their employment or move from full-time to part-time, but their coverage as an active employee may remain through the end of the month.
• Members cannot be simultaneously enrolled in COBRA and non-COBRA for the same coverage. Member snapshots that attempt to add overlapping coverage for a member will be rejected.
• In the case that not all family members are enrolled in COBRA but all changes are being communicated within the same member snapshot, active (non-COBRA) coverage and COBRA coverage should be sent as two separate coverage blocks.