Q.- We are a small employer subject to Pennsylvania mini-COBRA. I know that a person who is eligible for other group health coverage is not eligible to continue our coverage under PA mini-COBRA. We just terminated an employee. Her husband has health coverage that allows coverage for spouses. Do we still have to offer our mini-COBRA coverage to her since we know she is eligible for other coverage?
A.- Yes. The employer should still offer the mini-COBRA coverage even though the individual may not be eligible to actually elect the coverage due to the fact that she could be covered as a dependent under her husband's plan. The potential dependent eligibility does not impact the employer's obligation to offer the continuation coverage election. It just impacts individual's right to actually elect the mini-COBRA continuation coverage.