Q.- I know the deadlines for paying for COBRA coverage have been extended during the COVID-19 national emergency. Are we allowed to collect money from people who have used our COBRA coverage but have not paid?
A.- Yes. COBRA continuants who use coverage must pay for that coverage. Employers should be able to collect payment from continuants. However, since the deadlines for payment have been extended, continuants who have not paid for coverage from March 2020 onward are not yet “late” on their payment obligations. Employers may certainly ask for payment and remind continuants that they must pay for all months they had coverage and COBRA does not permit continuants to pick and choose the months they want coverage. COBRA runs for consecutive months.
