Q.- We terminated a member of our accounting department who stole a lot of money from our company. We will not be offering the employee COBRA since his termination is due to gross misconduct. He was covered under our health plan and will be losing coverage. Do we have to provide him any notice that he is not going to be offered COBRA?
A.- Yes. COBRA requires the plan to provide a notice of unavailability of COBRA coverage if the plan receives information about a qualifying event and then decides that the person will not be entitled to COBRA coverage.