COBRA Continuation Coverage

COBRA continuation coverage explained: eligibility, qualifying events, notice/election deadlines, cost rules, and alternatives like Marketplace plans or ICHRAs.
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Published on
June 17, 2025

If you’re a small business owner, HR manager, or employee, the term COBRA Continuation Coverage might sound a bit intimidating. Simply put, COBRA (Consolidated Omnibus Budget Reconciliation Act) continuation coverage is a federal law that provides employees and their families the option to continue their group health insurance coverage when it might otherwise end due to certain qualifying events. Navigating COBRA can feel like a maze, especially for small businesses without dedicated benefits teams. This article will walk you through the basics of COBRA, helping you understand what it means for employers and employees alike, and how you can manage it effectively.

What is COBRA Continuation Coverage?

The Basics

COBRA was enacted in 1986 to protect employees from losing their health benefits abruptly after events like job loss, reduction in work hours, or other life changes. For small businesses with group health plans, it requires them to offer employees (and their covered dependents) the choice to continue their health coverage temporarily, usually up to 18 months, sometimes longer.

Who Qualifies for COBRA?

Qualifying events that trigger COBRA include:  

  • Voluntary or involuntary job loss (except gross misconduct)  
  • Reduction in work hours  
  • Divorce or legal separation from the covered employee  
  • Death of the covered employee  
  • A dependent child ceasing to be a dependent under the plan’s terms  

Employees and their families who were covered under the employer-sponsored group health plan on the day before the qualifying event are generally eligible.

How Does COBRA Impact Small Business Owners and HR Managers?

Responsibilities of Employers

For small business owners and HR managers, offering COBRA continuation coverage means complying with specific federal rules:  

  • Notifying eligible employees within 14 days after a qualifying event  
  • Providing detailed election notices within 44 days from notification  
  • Maintaining coverage identical to active employees’ plan options during the COBRA period  
  • Managing premium collection and supporting documentation  

Failing to comply can result in penalties, so understanding these responsibilities is crucial even for small businesses.

Cost Considerations

Unlike traditional group health plans where employers often share premium costs, under COBRA, the employee usually pays the entire premium—both the employee and employer’s share—plus up to a 2% administrative fee. This can be costly for employees but allows uninterrupted health coverage.

What Does COBRA Mean for Employees?

The Benefits of COBRA

  • Continuity of Coverage: COBRA provides a safety net so employees and their families don’t face gaps in health insurance after job transitions or other changes.  
  • Same Plan Coverage: Coverage remains the same as when employed, preserving familiar benefits and providers.  
  • Time to Find Alternatives: Employees get extra time to explore new insurance options without rushing into decisions.

Important Considerations for Employees

  • Premium Costs: Since the employee shoulders the full premium plus fees, COBRA can be expensive versus employer-subsidized insurance.  
  • Enrollment Deadlines: Employees have 60 days from the election notice to choose COBRA coverage; missing this means losing the option.  
  • Limited Duration: COBRA is temporary, typically up to 18 months but can extend to 36 months under certain conditions.  

Employees need to weigh these factors and may want to compare COBRA with Marketplace plans or other alternatives based on cost and coverage needs.

Alternatives to Traditional COBRA for Small Businesses

The Rise of Individual Coverage HRAs (ICHRAs)

For small businesses, Traditional COBRA can be administratively complex and financially challenging. That’s where options like ICHRAs come in—these let employers give employees a fixed reimbursement amount to purchase individual health insurance that fits their needs, offering:  

  • Personalized plan choice for employees  
  • Predictable costs for employers  
  • Streamlined administration with platforms like SimplyHRA that automate compliance and reimbursements  

Short-Term Continuing Coverage Options

Some states have their own mini-COBRA laws that apply to smaller employers and might have different coverage durations or conditions. Employers should verify state-specific regulations that could provide alternative routes to COBRA.

Managing COBRA with SimplyHRA’s Support

How SimplyHRA Helps Small Businesses

We get it—juggling COBRA’s legal requirements and employee questions can bog down small businesses. SimplyHRA makes managing health benefits simpler by offering tools that:  

  • Automate notifications and paperwork to stay compliant  
  • Help employees comfortably choose and manage their coverage options  
  • We handle tax and compliance complexities so you don’t have to  

Enhancing Employee Benefits Experience

With SimplyHRA, employees enjoy:  

  • Freedom to select health plans that suit their families  
  • Assistance from broker teams in all states to guide plan choices  
  • Transparent reimbursement and expense management through easy platforms  

Why Understanding COBRA is Essential for Your Business and Staff

Small businesses might not have the scale or HR resources of large corporations, but understanding COBRA Continuation Coverage is fundamental to protecting your employees’ health security and staying legally compliant. It’s about more than just ticking regulatory boxes—offering or managing COBRA thoughtfully helps foster trust and stability among your workforce.

SimplyHRA empowers small businesses to navigate this complex terrain effortlessly, turning what used to be a headache into a streamlined, employee-friendly process.

Why SimplyHRA is Your Partner for COBRA Continuation Coverage

To wrap up, managing COBRA continuation coverage can be a maze for small business owners, HR managers, and employees alike. SimplyHRA is here to lighten the load by providing user-friendly, compliant solutions that let employers offer flexible, affordable health benefits without the usual hassle. Our platform automates compliance, offers personalized support, and gives employees the freedom to pick plans that truly fit their needs. Whether you’re just starting out or growing steadily, partnering with SimplyHRA ensures your health benefits program runs smoothly and keeps your team covered. Don’t let COBRA complexities slow your business down—reach out today for a consultation by emailing info@simplyhra.com or scheduling a call at https://www.simplyhra.com/contact.

Common Misconceptions about COBRA Continuation Coverage

COBRA Is Only for Large Employers

A frequent misunderstanding is that COBRA applies only to big companies. While it's true that the federal COBRA law covers employers with 20 or more employees, many states have "mini-COBRA" laws requiring smaller employers, often with 2–19 employees, to provide similar continuation coverage. So, even if your small business doesn’t meet the federal criteria, state regulations might still obligate you to offer COBRA-like benefits. Checking your state's Department of Insurance website or consulting with experts like SimplyHRA can clarify your responsibilities.

Employees Must Always Accept COBRA to Avoid Losing Coverage

Some think COBRA coverage is mandatory, but it’s entirely voluntary. Employees can decline COBRA benefits and instead opt for other coverage avenues such as enrolling in a spouse’s plan or purchasing insurance through the ACA Marketplace. That flexibility helps employees pick the most cost-effective or suitable option, but it also means employers need to clearly educate their workforce on deadlines and alternatives to avoid confusion or loss of coverage.

COBRA Notice and Election Process Explained

Timelines you Can’t Miss

When a qualifying event happens, employers have tight timelines:  

  • Within 14 days, employers must notify the plan administrator about the event.  
  • The plan administrator then has 44 days to send a COBRA election notice to affected employees.  
  • Employees have 60 days from this notice to decide whether to elect COBRA coverage.

Missing these deadlines can lead to complications, including loss of coverage for the employee or penalties for the employer. Using a platform such as SimplyHRA can help automate reminders and paperwork, ensuring your business stays compliant.

Information Included in COBRA Notices

The election notice isn’t just a formality. It includes critical info such as:  

  • How to elect COBRA coverage  
  • Coverage options and costs  
  • Payment deadlines and where to send premiums  
  • Information about rights to alternative coverage

Clear communication at this stage helps reduce confusion and improves employee satisfaction during what may be a stressful transition.

How COBRA Coordinates with Other Health Coverage

Interaction with Medicare

If an employee becomes eligible for Medicare after COBRA coverage begins, COBRA typically ends. Medicare becomes the primary payer, so employees should inform the COBRA administrator promptly to avoid dual premium payments.

Impact on Health Savings Accounts (HSAs)

Employees using HSAs should understand how COBRA affects their eligibility to contribute. While COBRA coverage counts as minimum essential coverage (MEC), enrolled individuals might not be considered "high deductible" under COBRA plans for HSA purposes. It’s a subtle but important distinction worth discussing with a benefits advisor.

Tax Implications of COBRA Continuation Coverage

For Employers

Premiums collected from employees under COBRA aren’t taxable income for the employer. However, employers must track and report these amounts correctly to the IRS, as they merely pass through the funds to the insurer or plan.

For Employees

Employees pay COBRA premiums with after-tax dollars unless reimbursed by an employer (rare under traditional COBRA). They cannot deduct these premiums from taxable income but might receive some relief through premium tax credits if they opt out and purchase Marketplace insurance—a complex decision worth consulting a tax professional.

Practical Tips for Small Business Employers Offering COBRA

Keep Accurate Employee Records

Ensuring you have up-to-date contact information and employment status records lets you avoid delays in notifications that could jeopardize compliance.

Train HR Staff or Consider Outsourcing Benefits Administration

Even small businesses benefit from having someone knowledgeable about COBRA regulations on their team. If hiring is not feasible, partnering with benefits platforms or brokers like SimplyHRA can prevent costly oversights.

Communicate Proactively with Employees

Preemptively informing employees about COBRA rights during onboarding or exit processes helps manage expectations and reduces confusion during transitions.

How SimplyHRA Simplifies COBRA Continuation Coverage Compliance

Automated Alerts and Notifications

SimplyHRA automates timely delivery of COBRA notices, keeping your business compliant without manual follow-up.

Seamless Integration with Payroll Systems

Our platform integrates with popular payroll providers, ensuring accurate premium handling and record-keeping, minimizing errors.

Dedicated Support for Small Business HR Managers

From answering complex regulatory questions to guiding employees through plan options, SimplyHRA’s team provides accessible expertise tailored to the needs of smaller companies.

The Future of COBRA and Small Business Health Benefits

Healthcare regulations frequently evolve. For example, recent legislation like the American Rescue Plan temporarily subsidized COBRA premiums for eligible workers during the COVID-19 pandemic. While such provisions may change, staying informed through trusted sources and partners is vital.

Small businesses should view COBRA not just as a compliance obligation but as part of a broader strategy to support employee well-being and retention. Solutions like SimplyHRA enable flexibility, affordability, and compliance in an ever-changing benefits landscape.

Wrapping Up: Trust SimplyHRA with Your COBRA Continuation Coverage Needs

Navigating COBRA Continuation Coverage can feel overwhelming with all its rules and deadlines. SimplyHRA stands out by easing burdens for small businesses and empowering employees with choice and clarity. Our technology automates compliance, aesthetics, and complexity so you can focus on running your business while keeping your team protected. Got questions or ready to improve your benefits experience? Contact us at info@simplyhra.com or schedule a consultation at https://www.simplyhra.com/contact. We’re here to help guide you every step of the way.

Frequently Asked Questions (FAQs) about COBRA Continuation Coverage:

Q: How long can COBRA coverage be extended beyond the initial 18 months?  

A: While the standard COBRA coverage period is 18 months, it can be extended in certain circumstances. For example, if a disabled individual qualifies, they may receive an 11-month extension totaling up to 29 months. Additionally, some qualifying events, like a second qualifying event within the initial coverage period, can extend COBRA coverage up to 36 months. It's important to notify the plan administrator promptly to take advantage of these extensions.

Q: Can part-time employees be eligible for COBRA coverage?  

A: COBRA eligibility depends on whether the employer sponsors a group health plan covering part-time employees who meet the plan’s eligibility criteria. If a part-time employee was covered under the employer’s health plan on the day before the qualifying event and the employer has 20 or more employees, that employee and their dependents may be eligible for COBRA continuation coverage. It varies based on company policies and plan terms.

Q: Are COBRA premiums tax-deductible for employees who pay them out-of-pocket?  

A: Generally, COBRA premiums are considered qualified medical expenses; however, employees can only deduct the portion of medical expenses (including premiums) that exceed 7.5% of their adjusted gross income, as an itemized deduction on their federal taxes. The deduction rules can be complex, so consulting a tax advisor to understand eligibility and maximize tax benefits is recommended.

Q: What happens if an employee doesn’t pay their COBRA premiums on time?  

A: Failure to pay COBRA premiums by the due date, including the 30-day grace period, usually results in termination of COBRA coverage. Employers or plan administrators must provide a notice of premium non-payment and termination. Once terminated, the individual loses access to the continuation coverage and typically cannot reinstate it. Timely payment is essential to maintain coverage.

Q: Does COBRA coverage provide dental and vision benefits?  

A: COBRA continuation coverage generally applies to any group health plan funded by the employer, including dental and vision plans, as long as these benefits were part of the original employer-sponsored group plan. Employees should check their specific plan details and with HR to confirm which benefits are covered under their COBRA continuation rights.

Q: How does COBRA coverage interact with unemployment benefits?  

A: Receiving unemployment compensation does not affect COBRA eligibility or continuation coverage. However, some states offer premium assistance subsidies for unemployment claimants to help cover COBRA premiums. Additionally, people who lose their job and qualify for unemployment may find Marketplace plans with subsidies to be a more affordable alternative.

Q: Can an employer reduce or eliminate COBRA premiums once coverage starts?  

A: Employers are permitted to subsidize COBRA premiums, but there is no federal requirement to do so (except during special programs like the ARP subsidies). If an employer chooses to reduce or pay any portion of COBRA premiums, it must apply uniformly to all eligible employees to avoid discrimination. This practice is rare among small businesses due to cost.

Q: Is COBRA coverage available for retiree health insurance plans?  

A: COBRA continuation rules explicitly apply to active employee group health plans. Retiree health insurance plans are generally not covered under COBRA. However, employees approaching retirement should review their benefits carefully and explore other options like Medicare or retiree-specific coverage.

Q: Can spouses and dependent children continue COBRA coverage if the employee becomes ineligible?  

A: Yes. Covered spouses and dependent children who were enrolled in the employer’s health plan on the day before a qualifying event such as divorce, legal separation, or loss of dependent status are eligible for COBRA continuation coverage independently, even if the employee does not elect continuation or has become ineligible themselves.

Q: How can employers verify that employees have secured alternative health coverage after COBRA ends?  

A: Federal COBRA regulations do not require employers to verify an employee's alternative health coverage after COBRA expires. However, some plan administrators might request documentation if available. Employees are encouraged to secure new coverage before COBRA ends to prevent gaps, but employers generally do not have enforcement responsibilities beyond COBRA compliance periods.

Q: Can COBRA coverage be used for spouses and dependents after the employee passes away?  

A: Yes. In the event of the covered employee’s death, spouses and dependent children who were enrolled in the group health plan can elect COBRA continuation coverage for a limited time, typically up to 36 months, to maintain their health benefits despite the loss of the employee.

Q: Are part-time seasonal employees covered under COBRA if the employer has 20 or more employees?  

A: Part-time and seasonal employees are eligible for COBRA continuation as long as they were enrolled in the employer’s health plan on the day before the qualifying event and the employer is subject to COBRA (generally 20 or more employees). However, eligibility depends on plan terms and employee status.

Q: How does COBRA coverage differ from state mini-COBRA laws?  

A: Mini-COBRA laws are state-level regulations that often apply to small employers with fewer than 20 employees, providing continuation coverage rights similar to federal COBRA but sometimes with different coverage durations, premium rules, and qualifying events. These laws serve to fill in gaps where federal COBRA does not apply.

Q: Is COBRA coverage available if an employee voluntarily quits?  

A: Yes. Voluntary termination of employment is a qualifying event under COBRA, so employees who resign can elect to continue their group health insurance through COBRA for the allowed coverage period.

Q: Can employees switch plans during COBRA coverage?  

A: Typically, no. COBRA continuation coverage requires maintaining the same health plan and benefits offered to active employees at the time of the qualifying event. Plan changes made by the employer during the COBRA period also apply to COBRA beneficiaries, but individual switching among different plans is not permitted until the next open enrollment or qualifying event.

Q: What paperwork is required for employees to elect COBRA coverage?  

A: When offered COBRA, employees receive an election notice explaining how to enroll, along with forms to accept or decline coverage. Employees must complete and return these forms within the 60-day election period. Keeping copies and sending responses via tracked methods can protect employees’ rights.

Q: Does COBRA apply if the employer offers a retiree health plan instead of a group health plan?  

A: COBRA specifically applies to active group health plans, not to retiree-only health plans. Retiree plans may have separate continuation rights governed by other laws or employer policies.

Q: What happens if an employee becomes eligible for Medicaid after electing COBRA?  

A: If an employee qualifies for Medicaid during COBRA coverage, they can maintain COBRA if they choose, but Medicaid generally provides broader coverage at lower or no cost. The decision depends on individual needs, although COBRA premiums might be costly compared to Medicaid benefits.

Q: How do employers handle COBRA coverage if the group health plan changes to a different insurer?  

A: COBRA continuation coverage must provide the same benefits as those offered to active employees. If the employer changes insurers, the COBRA beneficiary’s coverage generally transitions accordingly under the new plan terms, and employees should be notified of any changes.

Q: Are there any resources to help small businesses administer COBRA compliance?  

A: Yes. Several platforms and services specialize in COBRA administration for small businesses, including SimplyHRA, which offers automated notifications, premium management, and compliance support designed to ease the administrative burden on small employers.

Simplifying COBRA Continuation Coverage with SimplyHRA

Managing COBRA continuation coverage can be a complex and time-consuming task, especially for small businesses without dedicated HR or benefits teams. At SimplyHRA, we understand the challenges that small business owners and HR managers face because we’ve been in your shoes. Our platform simplifies the entire process—from automating compliance notifications to handling premium reimbursements—allowing you to offer your employees seamless health benefits without the administrative headaches.

Small business employees benefit too, gaining clear options and support to maintain their health coverage during transitions. By empowering employees to select plans that fit their lives and budgets, SimplyHRA helps boost satisfaction and retention. Our user-friendly tools and expert guidance have helped countless small businesses manage employer and employee health benefits programs efficiently, ensuring compliance while keeping costs predictable.

If you’re navigating COBRA coverage or exploring better ways to support your team’s health benefits, SimplyHRA is ready to partner with you. Reach out today to learn how we can make your benefits program easier to manage and more rewarding for everyone involved. Contact us at info@simplyhra.com or schedule a consultation at https://www.simplyhra.com/contact.

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