Q.- We are a small Pennsylvania employer with 10 employees. We are not subject to federal COBRA, but we do have to comply with PA mini-COBRA. Do we have to offer a continuation coverage election to our employees with a Medicare supplement policy who have a qualifying event?
A.- No. Medicare supplement policies are specifically excepted from the definition of group health plan for PA mini-COBRA purposes. No COBRA election under PA mini-COBRA has to be given for an individual who experiences a qualifying event when covered by a Medicare supplement policy, only.