Q. Our union employees are transferring to a Taft Hartley Plan. Do we have to offer them the right to continue our health coverage under COBRA?
A. No. We suggest that you consult your collective bargaining agreement to see if it addresses a continuation of coverage right upon this type of event. Absent an obligation under the bargaining agreement, a union employee losing eligibility for the company plan and obtaining coverage under a union plan is not a COBRA qualifying event. There are only certain events that give rise to continuation coverage opportunity under COBRA. For an employee, these events are termination of employment or reduction in hours of employment. Neither of these are at play in the situation you describe.