Q- We have an Employer Group Waiver Plan (EGWP) with a wrap that supplements CMS Medicare prescription drug coverage. Should we offer a COBRA coverage election for the wrap portion of the EGWP?
A- Probably yes. The "wrap" part of the EGWP may be subject to COBRA continuation coverage requirements. The "wrap" is an employer-provided group health plan supplementing Medicare. COBRA requires employer group health plans with at least 20 employees to offer continuation coverage to individuals who experience a COBRA qualifying event.