How long does COBRA continuation coverage last?

The duration of COBRA continuation coverage depends on whether the coverage is for the employee or the qualifying beneficiaries (covered dependents) and the type of qualifying event. Although COBRA regulations set the minimum duration periods, an employer's plan may provide longer periods of coverage beyond the minimum required period.

Employee Coverage

Under COBRA, employees themselves are only eligible for either:

• 18 months of coverage, due to termination of employment or a reduction in hours; or
• 29 months of coverage, if a qualified beneficiary on the plan is eligible for a disability extension (which occurs when the individual is determined to be disabled by the Social Security Administration before the 60th day of COBRA coverage and remains disabled for the initial 18 months of coverage). The 11-month extension begins at the conclusion of the original 18 months of coverage.

Additionally, under the Uniformed Services Employment and Reemployment Rights Act (USERRA), covered employees who enlist in the military or are called to active duty have COBRA-like coverage rights for themselves and their dependents that last for up to 24 months.

Dependent/Qualified Beneficiary Coverage

Dependents who are qualified beneficiaries are eligible for the same coverage durations above, but their coverage may extend even further in certain situations:

• 36 months of coverage, due to losing dependent-child status under the plan;
• Up to 36 months of coverage, when the qualifying event is termination of employment or a reduction in hours and the employee became entitled to Medicare less than 18 months before the qualifying event (where the 36 months is measured from the date the employee became entitled to Medicare); or
• Up to 36 months of coverage, when there is a second qualifying event during continuation coverage (the death of the covered employee; the divorce or separation of the employee and spouse; the covered employee becoming entitled to Medicare or loss of dependent-child status under the plan), where the 36 months is measured from the original COBRA continuation start date.