MMC Benefits Handbook
COBRA Eligibility and Enrollment
You are eligible for COBRA continuation if you are enrolled in Company-sponsored coverage and lose coverage due to a qualifying event. Note: An event is a qualifying event only if it causes a covered family member (beneficiary) to lose coverage.
Qualifying for Coverage/Qualifying Events
You and your covered family members can continue medical, dental, vision, Health Care Flexible Spending Account, Limited Purpose Health Care Flexible Spending Account, Employee Assistance Program (EAP), Best Doctors, Health Advocate and/or Healthyroads coverage for up to 18 months (Health Care Flexible Spending Account and Limited Purpose Health Care Flexible Spending Account coverage continues through the end of the calendar year of the qualifying event) if:
  • your employment terminates, unless you were terminated because of gross misconduct
  • you experience a reduction in hours.
Although not required by law, Marsh & McLennan Companies currently allows you to continue medical, dental, vision, Health Care Flexible Spending Account, Limited Purpose Health Care Flexible Spending Account, Employee Assistance Program (EAP), Best Doctors, Health Advocate and/or Healthyroads coverage for up to 18 months (Health Care Flexible Spending Account and Limited Purpose Health Care Flexible Spending Account coverage continues through the end of the calendar year of the qualifying event) if your status is changed to temporary from regular.
Your covered family members can continue coverage for up to 36 months if:
  • you become divorced or legally separated
  • you die while you are covered under an eligible plan
  • your family member no longer qualifies as an eligible family member
  • you are a retiree who participates in a Company medical plan and the Company files for bankruptcy.
The coverage period for eligible family members may be longer if you enroll in Medicare while covered by COBRA. If you experience an employment termination or a reduction of hours following Medicare enrollment, your spouse and dependent child(ren) who are your covered family members may elect COBRA coverage for up to 36 months from the date of Medicare enrollment or 18 months from the employee's termination or reduction in hours, whichever is longer.
Periods of Coverage:
Qualifying Events
Covered Family Members
Coverage
  • Termination of employment
  • Reduction of hours
  • Employee
  • Spouse
  • Dependent child
18 months*
  • Employee enrolled in Medicare
  • Divorce or legal separation from employee
  • Death of covered employee
  • Spouse
  • Dependent child
36 months
  • Loss of "dependent child" status
  • Dependent child
36 months
* In the case of individuals who are determined by the Social Security Administration to be disabled when they leave the Company or within the 60 calendar day COBRA election period, special rules may apply to extend coverage by an additional 11 months for the disabled individual and other individuals who are qualified beneficiaries with respect to the same qualifying event.
Participants in the Health Care Flexible Spending Account or Limited Purpose Health Care Flexible Spending Account may be eligible for COBRA coverage. This COBRA coverage may continue only until the end of the calendar year in which the qualifying event occurs and may not be continued into the next calendar year.
You can continue your Health Care Flexible Spending Account or Limited Purpose Health Care Flexible Spending Account for the balance of the calendar year if you go on an unpaid leave of absence or terminate employment.
You can continue coverage under the Employee Assistance Program, Best Doctors, Health Advocate and/or Healthyroads through COBRA if you experience a COBRA qualifying event and register your event within the legally allowable time frame.
Qualifying Event—Termination of employment
COBRA Due to Termination
How long is COBRA coverage available if I lose my job?
COBRA coverage is available for up to 18 months if your employment ends for any reason, unless you lost your job because of gross misconduct. COBRA coverage can be extended if there is a second qualifying event during the COBRA continuation period.
Disabled at Termination
If I'm totally disabled when I leave the Company, is there any difference in my COBRA coverage?
Yes. If you are disabled according to the Social Security Administration when you leave the Company or become disabled according to the Social Security Administration within the 60 calendar day COBRA election period, you and your covered family members can extend your COBRA coverage for an additional 11 months, for a total of 29 months from termination.
Note that your premiums are increased to 150% of the full group rate for those additional 11 months from the beginning of the 19th month through the end of the 29th month.
If a second qualifying event occurs within the first 18 months of the COBRA coverage, you pay the full group rate on an after-tax basis plus an additional two percent for administrative expenses from the beginning of the 19th month through the end of the 36th month. If a second qualifying event occurs within the 19th through 29th month of COBRA coverage extended for disability, your premiums will be increased by an additional 50 percent through the end of the 36th month.
Family or Medical Leave of Absence under FMLA
What happens if I take a family or medical leave of absence under FMLA?
Taking a family or medical leave of absence under the Family and Medical Leave Act (FMLA) usually will not constitute a qualifying event. A qualifying event occurs, however, if 1) you do not return to employment with the Company after the end of the FMLA leave and 2) without COBRA coverage, you or your covered family member would lose coverage before the end of the maximum coverage period.
Absence Due to Military Service
How will my absence from employment because of military service affect my coverage?
Your absence from employment because of military service is not a qualifying event under COBRA; however, you may elect to continue existing coverage for up to 18 months under the Uniformed Services Employment and Reemployment Rights Act (USERRA). For an absence of more than 30 days, you are not required to pay more than 102% of the full group rate. However, if our leave of absence is less than 31 days, you may not lose your coverage and will not have to pay more than the active employee contribution.
Company Involved in a Merger or Asset Sale
What happens to my coverage if the Company is involved in a merger or asset sale?
Special rules, policies and practices may apply if coverage is lost if the Company is involved in a merger or asset sale. You may be entitled to COBRA coverage from a buyer or the Company, depending on the transaction. A stock sale, however, is not a qualifying event for employees who continue their jobs after the sale, or for their family members.
COBRA Notification
When will I be notified about COBRA eligibility after my coverage ends because my employment terminates?
The Company has 30 days to notify its COBRA Administrator of death. Your covered family members will be notified of the right to continue coverage within 14 days of the date the Company's COBRA Administrator has been notified of the death.
Qualifying Event—Reduction in hours
Reduction in Hours
Can I continue my coverage under COBRA if I lose health coverage as a result of a reduction in hours?
Yes, you can continue coverage for you and your covered family members under COBRA for up to 18 months if your hours are reduced, and you are no longer eligible for coverage under a Company-sponsored plan. COBRA coverage can be extended if there is a second qualifying event.
Determination of COBRA Eligibility Due to a Reduction in Hours
When will I be eligible for COBRA coverage because of a reduction in hours?
You will be eligible for COBRA coverage if you experience a loss of coverage under your plan because of a reduction of hours; such as an absence from work due to disability, a temporary layoff or any other reason other than FMLA leave and your employment is not terminated.
Change from Regular to Temporary Status
Can I continue my coverage under COBRA if I lose health coverage as a result of a change in my employment status from regular to temporary?
Although not required by law, Marsh & McLennan Companies currently allows you to continue coverage for you and your covered family members under COBRA for up to 18 months if your employment status is changed and you are no longer eligible for coverage under a Company-sponsored plan. Your continuation coverage can be extended if there is a second qualifying event.
Non-resident Alien
Can I continue my coverage under COBRA if I am a non-resident alien employee of the Company?
No, you are not eligible for COBRA coverage if you are a non-resident alien employee of the Company who received no earned income from Marsh & McLennan Companies that constituted income from sources within the United States. Your spouse and dependent children will not be eligible for COBRA coverage through your status as a Marsh & McLennan Companies employee either.
COBRA Notification
When will I be notified about COBRA eligibility after my coverage ends because of a reduction in hours or a change from regular to temporary status?
The Company has 30 days to notify its COBRA Administrator of your reduction in hours or change from regular to temporary status. You and your covered family members will be sent written notification of your COBRA eligibility within 14 days of the date the Company's COBRA Administrator has been notified of your reduction in hours or change in employment status.
Qualifying Event—Medicare Entitlement
COBRA Eligibility for Family Members Due to Medicare Entitlement
What happens if I terminate employment and elect COBRA for myself and my family. Then, during the 18-month COBRA period, I become covered by Medicare?
Your COBRA coverage will end when you enroll in Medicare. Your family members will be able to continue their coverage for the remainder of the 18 months from the date of the original qualifying event (which was your termination of employment).
COBRA Eligibility for Active Employees Enrolling in Medicare
If I am an active employee who enrolls in Medicare, will I be entitled to COBRA continuation coverage?
No, an active employee's enrollment in Medicare is not a qualifying event that gives rise to COBRA eligibility. However, COBRA coverage is available for you and your covered family members if you subsequently experience a qualifying event (such as, termination of employment or reduction in hours).
The maximum coverage period for eligible family members ends on the later of:
  • 36 months from Medicare entitlement, or
  • 18 months (29 months if there is a disability extension) from the qualifying event.
Qualifying Event—Family Member No Longer Qualifies as an Eligible Family Member
Dependent Child Reaching Maximum Age
If my dependent child reaches the maximum age allowed under my plan, can my child continue coverage under COBRA?
Yes, your child can continue coverage under COBRA for up to 36 months, if your child reaches the maximum age under your plan.
If you are an active employee, a notification reminding you to report the COBRA qualifying event will automatically be sent to the Company's COBRA Administrator at the end of the calendar year in which your dependent child turns 26.
Family Members Lose Coverage at Annual Enrollment
If I drop my family member coverage during Annual Enrollment, are my family members eligible for COBRA coverage?
No. If you drop your family member coverage during Annual Enrollment, your family members are not eligible for COBRA coverage, because Annual Enrollment is not a qualifying event. You also cannot remove a family member from your coverage in anticipation of a qualifying event, such as a divorce.
Your family members are eligible for COBRA coverage if they are covered by the plan when you lose your coverage, or if they lose coverage because they are no longer eligible family members and you register the qualifying event.
Family Member Joining Military
If my dependent family member enters the military, is he or she eligible for COBRA coverage?
No. Your family member isn't eligible for COBRA after entering the military because your family member has not experienced a qualifying event.
Length of COBRA Continuation Coverage for Family Members
How long does COBRA coverage last for my family members if they do not qualify for coverage under my plan any longer?
Your family members can continue COBRA coverage for up to 36 months after they are no longer considered eligible for coverage due to a qualifying event, such as your divorce or legal separation or a dependent child reaching maximum age under the Plan.
Notification to Employer of Family Member Loss of Eligibility
When do I have to provide notification that my family member isn't eligible for coverage any more?
You or a family member must notify the Company of a divorce, legal separation or a child losing dependent status under the applicable plan within 60 calendar days of the qualifying event.
There are two ways to notify the Company and be eligible for COBRA coverage:
  • within 30 calendar days of the event: by going to Colleague Connect (https://colleagueconnect.mmc.com), or
  • after 30 calendar days, but within 60 calendar days of the later of the qualifying event or loss of coverage: Contact the Employee Service Center in writing at: Employee Service Center, P.O. Box 622, Des Moines, IA 50306-0622. You will not be refunded any of your contributions if you notify the Company after 30 calendar days.
Note: If the Company is not notified within 60 calendar days of the event, your family member who loses coverage will not be offered the option to elect COBRA coverage.
Family Member COBRA Notification
When will my family members be notified about COBRA eligibility?
The Company has 30 days to notify its COBRA Administrator of your qualifying event. You or your covered family member will be notified of the right to COBRA coverage within 14 days of the date the Company's COBRA Administrator has been notified of the qualifying event. A COBRA notification and enrollment form are mailed to you or your covered family members' last known address.
You must complete the COBRA enrollment form and return it as the form instructs.
You have 60 calendar days from the later of (1) the date you receive notice of your right to COBRA coverage, or (2) the date coverage would otherwise end to elect COBRA.
Qualifying Event—Divorce, Legal Separation, Termination of a Domestic Partnership
Continuing Family Coverage Through COBRA After a Divorce or Legal Separation
If I get divorced or legally separated, can my family get coverage under COBRA?
Yes, your spouse can continue coverage under COBRA when you are divorced or legally separated. If your children are no longer eligible dependents under the plan as a result of your divorce or legal separation, they can also continue coverage under COBRA if you register the event.
After a divorce or legal separation, COBRA coverage is available to your covered family members for up to 36 months.
Special Note on Domestic Partners
Do all plans cover domestic partners under COBRA?
Although not legally required to do so, Marsh & McLennan Companies extends COBRA continuation coverage to domestic partners of Marsh & McLennan Companies employees and/or their dependent children covered under the Company Benefits Program. (A few medical plans may not extend COBRA to domestic partners or their children; refer to the specific medical plan section to learn about COBRA availability.)
Notification to Employer of Divorce, Legal Separation, or Termination of a Domestic Partner
When do I have to provide notification that I am getting a divorce, legal separation or terminating my domestic partnership?
You or a family member must notify the Company of a divorce, legal separation or a child losing dependent status under the applicable plan within 60 calendar days of the qualifying event.
There are two ways to notify the Company and be eligible for COBRA coverage:
  • within 30 calendar days of the event: by going to Colleague Connect (https://colleagueconnect.mmc.com), or
  • after 30 calendar days, but within 60 calendar days of the later of the qualifying event or loss of coverage: Contact the Employee Service Center in writing at: Employee Service Center, P.O. Box 622, Des Moines, IA 50306-0622. You will not be refunded any of your contributions if you notify the Company after 30 calendar days.
Note: If the Company is not notified within 60 calendar days of the event, your family member who loses coverage will not be offered the option to elect COBRA coverage.
Qualifying Event—Death
Continuing COBRA Coverage for Family Members
If I die, can my family members continue their coverage under COBRA?
Yes, COBRA coverage is available to your covered family members for up to 36 months after your death.
Although not legally required to do so, as a special benefit, Marsh & McLennan Companies will contribute towards the monthly cost of COBRA coverage for your eligible family members who had previously been covered under Company medical and dental coverage during the first 12 months of the COBRA period provided they pay the required employee level contributions. After the first 12 months, your eligible family members can continue COBRA coverage for the remaining COBRA period, up to an additional 24 months, by paying the full group rate, plus an additional two percent for administrative expenses.
COBRA Notification
When will my family members be notified about COBRA eligibility after their coverage ends because of my death?
The Company has 30 days to notify its COBRA Administrator of death. Your covered family members will be notified of the right to continue coverage within 14 days of the date the Company's COBRA Administrator has been notified of the death.