Question of the Week - Timing of COBRA Start Date

Posted by BAS - 13 February, 2025

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Q: A former employee did not have to use coverage during the month she left employment. She wants to start COBRA at the beginning of the second month. We would be fine with this. Can we allow it?

A: No, COBRA and state continuation laws require that coverage be continuous with no lapse. COBRA coverage begins retroactively to the date group health plan coverage ended and continuants cannot choose to skip the first month and start coverage later. All required premiums must be paid from the start of COBRA to maintain continuous coverage.


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).

Topics: COBRA, COBRA Premium Billing, COBRA Administration, HR & Benefit Plans


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