Q.- We had an employee who was hired in October 2014 and was involved in a car accident a few weeks later. If he had been at work the whole time, his health coverage would have started December 1, 2014. He never came back to work. We added him to coverage thinking he was going to come back to work, and we forgot to remove him from coverage. At this point, the earliest date that our insurer will cancel his coverage is March 1, 2015. Do we have to send him a COBRA notice?
A.- Probably yes. Even though he was covered under your plan in error, continuation coverage should be offered since he was enrolled on the plan for at least one day. He was removed from coverage due to his termination of employment.