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Company goes from mini-COBRA to Federal COBRA - what happens to participants on mini-COBRA?


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Posted by Jeremy Davis on December 01, 2009 at 12:36:27:

If a company that was under 20 employees for 2008 and did not have to offer Federal COBRA in 2009 - then goes over 20 employees in 2009 and has to offer Federal COBRA in 2010.

If an employee was terminated in 2009 and accepted COBRA under mini-COBRA. And then the group begins administering the COBRA (or has a TPA do it) in 2010, what happens to the participant that was on mini-COBRA. Is that person still the responsibility of the carrier, or is it now the responsibility of the employer. Remember this person terminated prior to the company being required to offer federal COBRA and the participant elected under mini-COBRA.


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