Benefits and Compensation

COBRA Coverage—Qualifying Event Determines Length

Length of COBRA coverage varies according to the type of qualifying event. The following events qualify an individual for COBRA continuation coverage if the event causes loss of coverage for a qualified beneficiary:

  • Termination or reduction of hours of a covered employee other than because of the employee’s gross misconduct
  • Death of a covered employee
  • Divorce or legal separation of a covered employee
  • Entitlement of the covered employee for benefits under Title XVIII of the Social Security Act (Medicare)
  • “Aging out” of a child, (i.e., he or she ceases to be a dependent child under the age requirements of the plan)
  • Bankruptcy of the employer from which the covered employee retired

In general, benefits under COBRA continuation coverage begin on the date group health coverage is lost due to the qualifying event. Thus the beginning date for calculating how long the benefits last is the date of the qualifying event. COBRA continuation rights are usually limited to either 18 or 36 months (with the exception of bankruptcy as the qualifying event).

Here’s how it works out:

18 months. A qualified beneficiary is entitled to continue coverage under COBRA for a maximum period of 18 months if coverage would otherwise end due to:

  • Termination of employment; or
  • Reduction of hours

29 months. Certain disabled qualified beneficiaries and each family member who is also a qualified beneficiary but is not disabled are entitled to continue coverage under COBRA for a maximum period of 29 months if coverage would otherwise end due to termination of employment or reduction of hours. The 29-month maximum coverage period applies independently for each of the qualified beneficiaries.


COBRA compliance is easy … not.  Good news—Check out BLR’s October 19 webinar, COBRA 101: The Legal Dos and Don’ts of Complying With Federal COBRA Regs. Click here to find out more about this timely webinar.


36 months. A qualified beneficiary who is a spouse or dependent child is entitled to continue coverage under COBRA for a maximum period of 36 months if coverage would otherwise end due to:

  • Death of the covered employee
  • Divorce or legal separation from the covered employee
  • Entitlement of the covered employee for Medicare benefits; or
  • Disqualification of a child as a dependent because of age

OR:

If a second qualifying event which is the death of the covered employee, divorce of legal separation from the covered employee, or a child ceasing to be a covered dependent due to age occurs during an 18- or 29-month continuation period, the qualified beneficiary who is a spouse or dependent child is entitled to continue coverage under COBRA for a maximum period of 36 months measured from the first qualifying event. Medicare entitlement may also be a second qualifying event, but only if it would have resulted in a loss of coverage for the spouse or child if the qualified beneficiary who was the covered employee was still working enough hours to be covered as an employee.

Lifetime of retiree. A qualified beneficiary who is a retired employee and his or her spouse and dependent children are allowed to continue coverage for the retiree’s lifetime if coverage would otherwise end due to a bankruptcy proceeding plus an additional 36 months for a surviving spouse and dependent children.

COBRA compliance is clearly one of the trickiest challenges managers face, and no one’s likely to avoid its headaches for long. Fortunately, there’s a well-timed solution—BLR’s new October 19th webinar, COBRA 101: The Legal Dos and Don’ts of Complying with Federal COBRA Regs. Take it from the top and get practical, nitty-gritty on real-world COBRA compliance.

Join us on Wednesday, October 19—you’ll get the in-depth COBRA 101 webinarAND you’ll get all of your particular questions answered by our experts.

You’ll learn:

  • Basic coverage and eligibility requirements (they seem simple but they’re not)
  • Qualifying events (there are six types)
  • Timing and notices (they have to be on time)
  • Duration of coverage for six different qualifying events
  • Recordkeeping requirements and how to simplify the process
  • Practical approach to setting up your compliance program
  • When you need to call in an expert
  • Most common mistakes in COBRA compliance and how to avoid them


Eliminate COBRA headaches for good—with practical, field-tested techniques.  Attend October 19.Click here to find out more about this timely webinar.


COBRA 101
Monday, October 19, 2011
10:30 a.m. to 12:00 p.m. (PST)
11:30 a.m. to 1:00 p.m. (MST)
12:30 to 2:00 p.m. (CST)
1:30 to 3:00 p.m. (EST) 

Train Your Entire Staff

As with all BLR webinars:

  • One fee trains all the staff you can fit around a conference phone
  • You can get your (and their) specific phoned-in or emailed questions answered in Q&A sessions that follow each segment of the presentation
  • Your satisfaction is assured or you get a full refund

What if you can’t attend on that date? Pre-order the conference CD. For more information on the conference and the experts presenting it, to register, or to pre-order the CD, click here. We’ll be happy to make the arrangements. 

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