Q.- If a COBRA continuant’s coverage is ending before the 18 month maximum coverage period because he didn’t pay the monthly premium, do we have to give him advance notice before we terminate the coverage?
A.- No, advance notice is not required. The Department of Labor does require a plan send notice when coverage terminates before the end of the maximum COBRA period. This notice should be provided as soon as practical following the decision to terminate coverage. The notice is not required to be provided in advance of the termination.