Compliance Q&A: Understanding Dependent Coverage: COBRA, HSAs, and Qualifying Life Events

  • May 21, 2025
  • Posted by: Gus Altuzarra
  • Category: Compliance Q&A
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5.1.25 |  COBRA FOR DEPENDENTS AT AGE 26

 

Q. When a dependent reaches age 26, can they still remain on their parent’s plan under COBRA for 36 months?

A. Yes, when a dependent ages off their parent’s plan at age 26, this is a COBRA qualifying event for up to 36 months.


5.8.25 |  DEPENDENT HSA CONTRIBUTIONS

 

Q. If a father and adult daughter work for the same company, but the daughter is enrolled in the father’s family HDHP, would the daughter be allowed to contribute to their own HSA account? Are they considered to be a dependent?

A. Yes, if the father and child are both enrolled in a family HDHP, both the father and the child can independently contribute up to the family HSA limit to their own HSA. This is a different rule than the one that applies to a husband and wife in a family HDHP. In that case, the family contribution applies to both spouses together. But in this situation, both the father and child can each contribute the family HSA limit to their own HSA.

 

5.15.25 |  QUALIFYING LIFE EVENT

 

Q. An employee has waived benefits through open enrollment in December. Her stepdaughter, who has been on Medicaid, is now ineligible for it due to the family’s income increase. Because the stepdaughter is now ineligible for Medicaid, can our employee enroll herself and the stepdaughter now?

A. Yes, a stepchild is treated just like a natural child. A stepchild losing Medicaid would be a qualifying life event allowing the employee to enroll the stepchild and herself in the employer’s coverage.

 

Answers to the Question of the Week are provided by Kutak Rock LLP. Kutak Rock provides general compliance guidance through the UBA Compliance Help Desk, which does not constitute legal advice or create an attorney-client relationship. Please consult your legal advisor for specific legal advice.



Author: Gus Altuzarra
Gus is the CEO of Aston Sharp Insurance Services. In 2012, Gus founded Aston Sharp to start offering a larger scope of insurance products to his clients. With extensive history in life, disability, and long-term care planning, Gus acts as a full service insurance advisor. Gus initially started working with group employers offering assistance with the new changes mandated by the ACA (Affordable Care Act). The in-flow of new technology in recent years has created an opportunity to revolutionize an outdated industry. Gus now works to consolidate Employee Benefits, HR, Payroll, Work Comp, and ACA compliance all under one roof – delivering an easy-to-use technology driven solution to his clients.

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