Q: An employee covered under a group health plan turned age 65 in November 2025. Medicare Part A became effective November 1, 2025, and Part B will be effective July 1, 2026. The employee remains actively covered under the group plan, along with his spouse, and plans to retire on July 1, 2026, at which time coverage under the group plan will end. Is the spouse eligible for up to 36 months of COBRA coverage? If so, when does the 36-month period begin, November 2025 or July 1, 2026?
A: Yes, the spouse may be eligible for up to 36 months of COBRA continuation coverage. The 36-month maximum coverage period begins on November 1, 2025, the date the employee first became entitled to Medicare.
Under COBRA rules, if a covered employee becomes entitled to Medicare before experiencing a qualifying event such as termination of employment or reduction of hours, qualified beneficiaries other than the employee (e.g., the spouse) may receive an extended coverage period. Specifically, coverage may last until the later of:
- 36 months from the date of the employee’s Medicare entitlement; or
- 18 months (or up to 29 months if a disability extension applies) from the date of the subsequent qualifying event (retirement or reduction of hours).
In this scenario, the 36-month period is measured from November 1, 2025, not from the retirement date of July 1, 2026.
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This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.
