COBRA: Now is a Good Time to Look Back

COBRA generally applies to all private-sector group health plans maintained by employers that have at least 20 employees on more than 50 percent of its typical business days in the previous calendar year. COBRA also applies to plans sponsored by state and local governments.

Who counts? Both full and part time employees count towards your determination as to whether your company is subject to COBRA regulations for 2018.  Each part-time employee counts as a fraction of a full-time employee, with the fraction being equaled to the number of hours that part-time employee worked divided by the hours an employee must work to be considered full time. Also, it does not matter if the employee is covered under the health plan or not. It is based on hours worked.


Now is a good time to look back to see if your company needs to continue to comply with COBRA regulations in 2018.

If you determine that you did not have 20 or more employees for more than 50 percent of your typical business days in 2017, you can stop complying with COBRA for 2018. If you are not required by Federal law to continue to offer COBRA continuation, you should not voluntarily offer COBRA.

If you determine that you did have 20 or more employees for more than 50 percent of your typical business days in 2017, you will need to comply with COBRA for 2018. You can request a price quote for BASIC COBRA here.

What does this mean if I no longer have to offer COBRA?

Current COBRA Participants must to be allowed to finish their COBRA timeframes. For example, if John Smith’s COBRA started July 1, 2017 and ends December 31, 2018, as long as he makes timely payments, then he must be allowed to continue his group health plan until his COBRA timeframe is exhausted.

  1. you have terminations that occur on or after January 1, 2018, those employees are not eligible for COBRA. (No Qualifying Event Notice should be sent.) You should notify your carrier(s) and broker that you are no longer required to offer COBRA.

If you have new hires or a voluntary removal of coverage, a notice is no longer required to be sent.

For more information, click on the following links:

DOL Frequently Asked Questions – COBRA Continuation Coverage

BASIC’s COBRA Administration reduces your risk and frees valuable time and resources, allowing you to focus on your active employees and operations. Since 1995, our clients nationwide rest easy knowing that their COBRA administration is being handled consistently and accurately by experts.

Learn More About BASIC’s COBRA Administration

Request a Proposal for BASICs COBRA Administration