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Qualified Beneficiaries and Qualifying Events under Mini-COBRA

Qualified Beneficiaries
Qualified Beneficiaries and Qualifying Events under Mini-COBRA

Mini-COBRA benefits must be provided to Qualified Beneficiaries upon the occurrence of a Qualifying Event. Qualified Beneficiaries are generally individuals who are covered under a small group health benefit plan on the day before the Qualifying Event. Qualified Beneficiaries can be:
  1. an employee
  2. the spouse of an employee
  3. the dependent child of an employee 1
Qualifying Events are events which would cause a Qualified Beneficiary to lose health coverage if Mini-COBRA benefits were not available. The type of Qualifying Event will determine: (1) who is eligible for Mini-COBRA and (2) the length of time that the benefits must be offered. See the chart below for a summary. 2
 
Qualifying Event QUALIFIED BENEFICIARY LENGTH OF TIME COVERAGE MUST BE OFFERED
death of employee spouse
dependent child
36 months
termination of employee's employment (other than by reason of employee's gross misconduct) employee
spouse
dependent child
18 months
reduction in hours worked by employee employee
spouse
dependent child
18 months
divorce or legal separation of the employee from his/her spouse spouse
dependent child
36 months
employee becomes entitled to Medicare spouse
dependent child
36 months
dependent child is no longer considered to be dependent under the small group health benefit plan dependent child 36 months

Note: There is a special rule for Qualified Beneficiaries who are determined to be disabled under the Social Security Act at the time of a Qualifying Event involving termination or reduction in work hours. Coverage may be extended from 18 months to 29 months if notice of such determination is given to the small group carrier within 60 days of the date of such determination and before the end of the 18-month period. Disabled individuals may be required to pay 150% of the premium for Mini-COBRA coverage after the initial 18-month period expires. Individuals must also notify the small group carrier within 30 days of the date of a final determination that they are no longer disabled.
 

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