Department of Personnel Administration

Benefits Administration Manual

Consolidated Omnibus Budget Reconciliation Act (COBRA)

402. Qualified Beneficiary

The term "qualified beneficiary" means, an individual that is eligible to continue group coverage because of a qualifying event. Except for the exception listed below on newborns and adopted children, the individual must be covered under the plan at the time of the qualifying event. If the individual is not covered, he/she is not eligible for COBRA continuation coverage.

Eligible Individuals
  • Current employees
  • Former employees
  • Retired employees
  • Spouses*
  • Dependent children**
  • Newborn or child placed for adoption (deemed a qualified beneficiary, although not covered at time of the qualifying event)
Ineligible Individuals
  • Non-resident aliens (with no U.S. income)
  • Individuals (not qualified beneficiaries) under the plan because of another qualified beneficiary's election

* Domestic partners (eligible based on State of California legislation, not federal COBRA law).

** National Medical Support Notice (NMSN) and Qualified Medical Child Support Order (QMCSO)

Employers are required to provide group health coverage (includes medical, dental, and vision coverage) to children of employees when ordered to do so by state authorities. To ensure that coverage is provided, state, local courts, and agencies can issue medical child support orders.

The Personnel Office may see two types of medical support orders: state domestic relations court and agency orders, referred to as "Qualified Medical Child Support Order" (QMCSO), and orders issued by child support enforcement agencies on standardized forms called "National Medical Support Notice" (NMSN). A child enrolled in group coverage when ordered by a NMSN or QMCSO is deemed a qualified beneficiary under COBRA law, regardless of his/her status as a dependent of the covered employee.

The Personnel Office should send an Initial General Notice to the custodial parent or guardian ("in care of the child") or agency that sent the NMSN or QMCSO (as a substitute, if child's address is unknown).

Updated February 14, 2011 at 1:34 PM.