Q.- We offer a self-funded health plan that covers employees in different states. A COBRA participant who lives in Connecticut thinks we have to offer him 30 months of continuation coverage under Connecticut law. His qualifying event was termination of employment which entitled him to 18 months of COBRA. Do we have to give him 30 months of coverage just because he lives in a state that has a state COBRA law?
A.- No. The Connecticut (and other) state continuation of coverage laws are promulgated under the state insurance codes. They apply to insured plans written in the particular state. Since you offer a self-funded plan, you are not subject to Connecticut state insurance laws and do not have to offer the 30-month extended coverage period to your COBRA continuant who lives in Connecticut.