This SOP governs COBRA continuation coverage administration for the Unity Care Member Plan Master Trust. Varipro serves as the COBRA Third-Party Administrator. This SOP defines qualifying events, notification responsibilities and timelines, election and payment procedures, monthly reconciliation, premium rates, and offboarding procedures.
Applies to all participating employer groups and their employees covered under the Unity Care Member Plan Master Trust. Covers all COBRA qualifying events, general notices, election notices, premium collection, and enrollment reconciliation with Allied Benefit Systems.
Operations must notify Varipro of all new employer groups at onboarding and of all qualifying events within the timelines specified in Section 5. Varipro does not receive qualifying event notices directly from employers — all notifications route through Operations.
| Qualifying Event | Qualified Beneficiaries | Maximum Coverage Duration |
|---|---|---|
| Termination of employment (voluntary or involuntary, other than gross misconduct) | Employee, spouse, dependents | 18 months |
| Reduction in hours (no longer eligible for coverage) | Employee, spouse, dependents | 18 months |
| Divorce or legal separation from covered employee | Spouse, dependents | 36 months |
| Death of covered employee | Spouse, dependents | 36 months |
| Employee becomes entitled to Medicare (Part A or B) | Spouse, dependents | 36 months |
| Dependent child loses dependent status under plan terms | Dependent child | 36 months |
| Employer bankruptcy (under Title 11) — if covered retirees | Retired employee, spouse, dependents | 36 months (or life of retiree) |
The participating employer (Plan Administrator) notifies Operations of any qualifying event within 30 days of the event date. Notification must include: employee name, event type, event date, coverage end date, and names of all affected qualified beneficiaries (including dependents).
Operations forwards qualifying event information to Varipro within 14 days of receiving notice from the employer. Operations uses Varipro's qualifying event notification form or online portal. Operations retains a copy of the notification and confirmation from Varipro.
Varipro mails a COBRA election notice to the qualified beneficiary at the last known address within 14 days of receiving Operations' notification. The election notice must include: coverage options, premium amounts (102% of applicable cost), election deadline, and payment instructions.
The qualified beneficiary has 60 days from the later of: (a) the date coverage was lost, or (b) the date the election notice was sent, to elect COBRA continuation coverage. Operations monitors election status via Varipro's reporting portal.
After electing COBRA, the qualified beneficiary has 45 days to submit the first premium payment (retroactive to coverage loss date). Subsequent premiums are due on the first of each month with a 30-day grace period. Varipro tracks payments and notifies Operations of delinquencies.
Varipro transmits enrollment updates to Operations, who confirms that Allied's enrollment records reflect COBRA enrollees. Operations reconciles Varipro's active COBRA roster against Allied's enrollment data monthly (see Section 7).
COBRA premiums are set at 102% of the applicable cost of coverage (employer + employee share of premium, plus 2% administrative fee). Varipro calculates and bills COBRA premiums based on the plan option the qualified beneficiary elects to continue.
Operations performs a monthly COBRA reconciliation on or before the 15th of each month:
Per COBRA regulations, a general COBRA notice must be provided to newly covered employees and their spouses within 90 days of the date coverage begins. Varipro generates and mails the general COBRA notice for each employer group upon notification from Operations at onboarding. Operations confirms general notice distribution with Varipro at each new employer setup.