COBRA offering guidelines

For companies with 20 or more employees

Qualifying events

Duration of coverage

Work hour reduction

  • Applies to all covered employees going from full-time to part-time
  • Strike
  • Non-FMLA medical leave
  • Military leave

18 months

Termination (Voluntary or Involuntary)

  • Applies to all covered members
  • Layoff
  • Excludes termination for gross misconduct

18 months

Employer files Chapter 11 - Bankruptcy

Applies to retirees and their covered dependents only

36 months


Spouse and any dependent children losing coverage are eligible

36 months

Employee becomes Medicare-eligible

Spouse and any dependent children are eligible

36 months

Subscriber death

Applies to all surviving dependents

36 months

Dependent loses coverage when reaching maximum age under the plan

Applies to dependent children and grandchildren who have reached the maximum age under the plan

36 months

If your employee or a dependent is determined by the Social Security Administration (SSA) to have been disabled at any time during the first 60 days of COBRA coverage, the employee must notify you (the plan administer) within 60 days of SSA’s determination. If the employee or a dependent chooses to extend COBRA coverage, it must be elected before the end of the 18-month period by giving written notice (of election to extend COBRA coverage). All members can receive up to an additional 11 months of COBRA coverage, for a total maximum of 29 months.

An individual may elect COBRA regardless of whether he or she is covered by another group health plan or is entitled to Medicare. COBRA must be offered and cannot be discontinued due to having other coverage or Medicare if the individual was enrolled in other coverage or Medicare before electing COBRA. If the individual enrolls in other coverage or Medicare after electing COBRA, COBRA can be discontinued in that situation.

Medicare will always be primary for an individual on COBRA because he or she is no longer actively at work, and Dean Health Plan will be the secondary payer of claims. This means that a Medicare carve-out (reduced) rate will be charged rather than the full active employee rate. If you know the individual has Medicare at the time of enrollment in COBRA coverage, please make sure that his or her Medicare numbers are submitted to us so claims are paid properly and premium is charged accordingly.