COBRA Events, Notices, and Deadlines

Benefits Concepts / PrepToPay
Continuation Coverage

COBRA Events, Notices, and Deadlines

COBRA administration is a sequence problem: identify the covered plan, the qualifying event, who is a qualified beneficiary, when notice duties begin, and how long continuation may last.

Reviewed July 29, 2026 · Source-led practitioner reference

Start with plan coverage

Federal COBRA generally applies to private-sector group health plans maintained by employers with at least 20 employees on more than 50 percent of typical business days in the prior calendar year. State and local government plans follow the public-sector COBRA route administered by CMS. Federal government and certain church plans follow different rules.

Qualifying events and maximum periods

Event Potential qualified beneficiaries General maximum
Termination other than gross misconduct or reduction in hours Employee, spouse, dependent child 18 months
Death, divorce or legal separation, or loss of dependent status Spouse and/or dependent child 36 months
Employee Medicare entitlement in qualifying circumstances Spouse and dependent child Up to 36 months

An event matters only when it causes a loss of coverage under the plan. Disability extensions and second qualifying events can modify the ordinary period when their conditions and notice rules are satisfied.

Election and payment timing

  • Each qualified beneficiary receives an independent election right.
  • The election period must be at least 60 days, measured from the later of the election notice or the date coverage would otherwise end.
  • The initial premium payment period must be at least 45 days after election.
  • Subsequent monthly payments receive at least a 30-day grace period.
  • The usual maximum premium is 102 percent of the total applicable cost; special disability-extension pricing can differ.
Administration trap: Do not treat the termination date, coverage-loss date, notice date, and election deadline as one date. Document the event and every handoff between employer, plan administrator, COBRA vendor, and qualified beneficiary.

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Primary sources

Educational reference only. Plan documents, governing law, agency guidance, and plan-specific professional advice control.

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COBRA execution also sits inside a broader plan-governance system. Review the fiduciary process behind plan administration.

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