Q.- A dependent aged off of our plan but we forgot to remove him from coverage. The insurer will not terminate him back to the date of his 26th birthday. Since he had several extra months of coverage, do we have to offer him a COBRA election, and when should the 36 months of coverage start?
A.- A loss of dependent child status under is a qualifying event if it causes the child to lose coverage. The date of the qualifying event is the date coverage is lost in connection with the event. It is our understanding that if coverage was not lost on the 26th birthday, no event occurred at that time and the event occurred when the child actually did lose coverage under the plan (when you entered the termination). That date should most likely be the start date for the COBRA coverage and start the running of the 36 months of COBRA.