Q.- We terminated an employee October 15 and gave him a COBRA election. His active coverage went through the end of October. He has contacted us and said he does not need coverage for November, but would like coverage for December. Do we have to allow this?
A.- No. COBRA requires that coverage be continuous with no lapse between the loss of coverage in connection with the qualifying event and the start of COBRA coverage. He must elect and pay for coverage back to November 1 in order to continue his coverage under COBRA into December.