Q.- Our former employee and her child were offered COBRA coverage. The employee declined coverage but the child elected and became a qualified beneficiary. The child had 18 months of coverage from the date of the employee’s termination. Does the child experience a second qualifying event when he reaches age 26 and does he have to be given an additional 18 months of COBRA coverage?
A.- The child will have a second qualifying event upon his 26th birthday, even though the former employee did not elect continuation coverage and the child would not lose COBRA coverage. The child will be entitled to 36 months of coverage from the date of the original qualifying event.
This is because for the second qualifying event rule, you look to whether the event would cause a loss of coverage under the plan if the first event didn’t occur and if the qualified beneficiary were still covered by the plan due to the employee’s current employment. In that case, the child would lose coverage at age 26 so it is considered a second qualifying event.
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