The 8 COBRA Qualifying Events
| Qualifying Event | Who Is Affected | Max Coverage Period |
|---|---|---|
| Termination of employment (other than gross misconduct) | Employee, spouse, dependents | 18 months |
| Reduction in hours below plan eligibility | Employee, spouse, dependents | 18 months |
| Death of covered employee | Spouse, dependents | 36 months |
| Divorce or legal separation | Spouse, dependents | 36 months |
| Employee becomes entitled to Medicare | Spouse, dependents | 36 months |
| Dependent child loses dependent status | Dependent child | 36 months |
| Employer bankruptcy (retiree coverage) | Retirees, spouses, dependents | Until death of retiree |
| Disability extension (SSA determination) | Employee, spouse, dependents | 29 months (11-month extension) |
Employer Notification Obligations
When a qualifying event occurs, the employer must notify the plan administrator within 30 days. For qualifying events that the employer controls (termination, reduction in hours, death, Medicare entitlement), the employer has direct knowledge and must notify the plan administrator promptly.
Employee/Qualified Beneficiary Notification
For qualifying events that the employer may not know about — divorce, legal separation, or a dependent losing eligibility — the employee or qualified beneficiary must notify the plan administrator within 60 days of the event. The plan document must describe this notification requirement.
Watch Out
Employers frequently miss COBRA qualifying events because they do not have a process for identifying them. A termination is obvious — but a reduction in hours that drops an employee below the plan's eligibility threshold may not be. Implement a process to identify all qualifying events, including hours reductions, and notify the plan administrator within 30 days.