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Reference
Appendix and Legal Notices
Period of COBRA Coverage
COBRA continuation coverage is temporary. The length
of time for which COBRA continuation coverage will be
available (the “maximum period” of continuation coverage)
depends on the type of qualifying event, as shown in the
following chart:
Qualifying Event
Maximum Period of COBRA Continuation Coverage
Your termination of employment and/or reduction in hours
of employment
18 months
You or your covered legal spouse, registered domestic
partner or child qualify for a disability extension
29 months
Your divorce, legal separation, termination of domestic part-
nership, death or becoming entitled to (enrolled in) Medicare
benefits
36 months
Your covered dependent child’s loss of dependent status
36 months
However, you or your covered legal spouse’s, registered
domestic partner’s or child’s COBRA continuation coverage
period may be terminated before the maximum period of
coverage to which you were entitled if one of the following
events occur; in this case your coverage will end on:
• The date on which a premium payment was due but
not paid.
• The date after you or your legal spouse, registered
domestic partner or child first becomes covered
under another employer’s group health plan without
an exclusion or limitation affecting coverage of his or
her pre-existing condition, if any, provided he or she
becomes covered after his or her election of COBRA
continuation coverage.
• The date after you or your legal spouse or registered
domestic partner first becomes entitled to Medicare
benefits (under Part A or Part B, or both), provided
you or he or she becomes covered after his or her
election of COBRA continuation coverage.
• The date the Company terminates all of the group
health plans.
• For the health flexible spending account, the last day
of the plan year in which the qualifying event occurs.
If you or your covered legal spouse’s, registered
domestic partner’s or child’s COBRA continuation
coverage is terminated for any reason before the
maximum period of coverage to which you were
entitled, you or your covered legal spouse, registered
domestic partner or child will be notified of that fact
and provided with an explanation of why COBRA
continuation coverage was terminated.
Special rule for Medicare entitlement:
If you
become entitled to Medicare (Part A or B) while you
are still employed by the Company (but not more
than 18 months before the qualifying event) and you
then lose your health coverage because of a quali-
fying event that is a termination or reduction in your
hours of employment, then your covered legal spouse
or registered domestic partner and children may elect
COBRA continuation coverage for the balance of the
36 month period starting when you became entitled
to Medicare, or 18 months from your later termination
or reduction in hours of employment, whichever
period is longer.
You or your covered legal spouse, registered
domestic partner or child, or a person acting on your
or their behalf must provide notice of your entitlement
to Medicare benefits (under Part A, Part B, or both)
within the time limit and in the manner described
below for second qualifying events.
For example, if a covered employee becomes entitled
to Medicare eight months before the date on which
his or her employment terminates, COBRA continu-
ation coverage for his or her covered legal spouse or
registered domestic partner and children remains in
effect for up to 36 months after the date of Medicare
entitlement. This is equal to 28 months after the date of
the qualifying event (36 months minus eight months).
Otherwise, when the qualifying event is the end of
employment or reduction of the employee’s hours of
employment, COBRA continuation coverage generally
lasts for only up to 18 months. There are two ways in
which this 18-month period of COBRA continuation
coverage can be extended, as explained below.
