COBRA Qualifying Events: What Triggers Employee Rights
Learn which events require COBRA continuation coverage, how long coverage lasts, notification deadlines, and your obligations as an employer for each qualifying event type.
When employees leave your company or experience certain life changes, they might lose their health insurance coverage. That's where COBRA comes in - but only for specific situations called "qualifying events." Understanding these events and your obligations can save your business from costly penalties and help departing employees navigate a difficult transition.
What Are COBRA Qualifying Events?
Think of COBRA qualifying events as specific life circumstances that trigger an employee's right to continue their health insurance coverage at their own expense. Not every situation qualifies - COBRA law defines exactly which events give employees this continuation right.
These events fall into two categories: those affecting the employee directly, and those affecting their covered family members. Each type has different coverage periods and notification requirements that employers must follow.
Employee-Related Qualifying Events
Voluntary or Involuntary Termination: When an employee quits or is fired for reasons other than gross misconduct, they can continue coverage for up to 18 months. This includes layoffs, resignations, or being let go for performance issues (but not for serious violations like theft or fraud).
Reduction in Hours: If you reduce an employee's hours below the threshold for benefits eligibility, they qualify for COBRA. This often happens when full-time employees move to part-time status. Coverage duration is also 18 months.
Disability Extension: If a terminated or reduced-hours employee is determined disabled by Social Security within 60 days of their qualifying event, they can extend COBRA coverage to 29 months total.
Family Member Qualifying Events
Employee's Death: When a covered employee dies, their surviving spouse and dependent children can continue coverage for up to 36 months.
Divorce or Legal Separation: If a covered employee divorces, the former spouse loses eligibility for the employee's plan but can elect COBRA for up to 36 months. The employee and any dependent children keep their regular coverage.
Child Losing Dependent Status: When a dependent child reaches the plan's age limit or no longer meets dependency requirements, they can continue coverage for 36 months.
Medicare Entitlement: When a covered employee becomes entitled to Medicare, their spouse and dependent children can elect COBRA for up to 36 months, even though the employee may keep employer coverage.
Notification Requirements and Deadlines
For termination, layoffs, or hour reductions, employers must notify the plan administrator within 30 days. However, for family-related events like divorce or a child aging out, the employee or family member must notify the employer within 60 days of the event.
Once notified, employers have 14 days to provide COBRA election notices to qualified beneficiaries. Employees then have 60 days to decide whether to elect COBRA coverage and an additional 45 days to make their first premium payment.
Why This Matters for Your Business
Proper COBRA administration protects your business from significant penalties - the Department of Labor can fine employers up to several hundred dollars per day for each violation. More importantly, it shows departing employees that you care about their wellbeing during transitions, which protects your company's reputation in the community.
Many Long Island businesses find COBRA administration overwhelming because the rules are complex and deadlines are strict. Missing a notification deadline or providing incorrect information can expose your company to lawsuits and penalties.
What Employees Value About COBRA
While COBRA premiums are expensive for employees (they pay the full cost plus a small administrative fee), it provides crucial bridge coverage. Employees value knowing they won't face a gap in health insurance while job hunting or dealing with family changes.
For employees with ongoing medical conditions or family members receiving treatment, COBRA can be invaluable. It allows them to keep their current doctors and continue treatment plans without interruption.
Key Considerations for Employers
COBRA applies to group health plans maintained by employers with 20 or more employees. However, New York has its own mini-COBRA law that covers smaller employers, so most Long Island businesses have some form of continuation coverage obligations.
You'll need systems to track qualifying events, calculate coverage periods, and manage premium collections. Many employers outsource this administration because the legal requirements are detailed and mistakes are costly.
Consider how you'll handle communications with former employees and their families. These are often people going through difficult transitions, so clear, compassionate communication reflects well on your business.
How Benton Oakfield Simplifies COBRA Administration
Managing COBRA qualifying events doesn't have to overwhelm your business operations. Our plan administration services handle the complex tracking, notifications, and deadlines so you can focus on running your business.
We work with Long Island employers to create systems that automatically identify qualifying events, generate required notices, and manage the entire COBRA process. Our team stays current on federal and New York state requirements, so you don't have to worry about compliance changes.
When qualifying events occur, we handle the employee communications with the sensitivity these situations require, protecting your company's reputation while ensuring full legal compliance.
Ready to streamline your COBRA administration? Contact our team to learn how we can remove this administrative burden from your business while ensuring your employees receive the support they need during transitions.
Compliance Note: Benefit plan rules and tax implications vary based on company size and location. This guide is for educational purposes only. Please contact your Benton Oakfield representative to discuss how this applies to your specific situation.
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