Deadlines

One calendar keeps every layoff deadline in view.

A layoff starts several benefits deadlines at once. Here is the sequence, from separation date to year-end filings.

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The Sequence

From separation date to year-end.

First 30 Days

The employer’s notice to the COBRA administrator is generally due within 30 days of the qualifying event.

The Following Weeks

Election notices go out, the election window runs at least 60 days, and the first premium is generally due 45 days after election.

Year-End

ACA reporting forms follow after year-end for the people who left.

In Practice

How it plays out.

A layoff produces a cluster of dates in the first weeks, then a long quiet stretch, then year-end filings. The risk is in the first part, when several clocks start at once, and in the last part, which is easy to forget.

A good calendar has one line per person, not one for the group. Coverage end dates and notice dates can differ by person, especially when separations happen across several weeks.

It also has an owner for each date. A date nobody owns is a date that gets missed.

The Support

How we help.

A broker should take work off a smaller HR team, not add to it.

Dates Per Person

We help set dates for each person affected, not one date for the group.

One Calendar

We keep the dates with the rest of the account.

Year-End Handoff

We help carry the separations into year-end reporting.

First Steps

Build the calendar.

Start With Separation Dates

List each person and their separation date.

Add Coverage End Dates

Add the date each plan ends coverage.

Add the Notice Clocks

Add the 30-day, 14-day, 44-day, 60-day and 45-day dates that apply.

Add Year-End Items

Add ACA reporting and any plan-level filings.

Common Mistakes

Mistakes that cost money.

One Date for the Group

People separated on different days have different clocks.

No Owner Per Date

Ownerless dates are the ones that slip.

Forgetting Year-End

Reporting for people who left is still due after year-end.

Let’s Get to Work

Is HR carrying more than it should?

Tell us what changed, and we will show you what to take off the desk.

What to bring

Your renewal letter
Your census
Your current plan documents
Your renewal date

Rough answers are fine. We build the numbers from there.

Sources

Laws and rules referenced

COBRA: ERISA §§ 601-608, 29 U.S.C. §§ 1161-1168

ACA employer reporting: 26 U.S.C. § 6056

CFH Insurance Consultants

An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.

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