Question of the Week - COBRA Start Date

Posted by BAS - 06 November, 2025

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Q.- An employee terminated in August. She elected COBRA but took her full 60 days to do so. She wants her payments to be applied starting in November since she hadn’t elected COBRA in September or October and doesn’t need coverage for those months. Do we have to allow this?

A.- No. While qualified beneficiaries have 60 days to elect COBRA and an additional 45 days to pay for that coverage, reinstatement goes back to the date coverage was lost. Qualified beneficiaries cannot get out of payment for beginning months of COBRA just because they take their time making their COBRA election.


Benefit Allocation Systems (BAS) provides best-in-class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.

MyEnroll360 can Integrate with any insurance carrier for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and many others), and integrate with any payroll system for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and many others).

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.

Topics: COBRA, COBRA Premium Billing, COBRA Administration, Question of the Week


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