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"frozen" HRA and COBRA

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Employer has an HRA that they are trying to phase out.  The plan has been closed to new participants since 2004.  The employer ceased contributions to the plan as of 12/31/16.  Active participants with balances may "spend down" their accounts over a certain period of time based on their account balance (higher balances get longer to spend down).  Terminated employees forfeit their balance upon termination, subject to a run-out period following termination for expenses incurred prior to termination.  My question is how to administer COBRA for this plan.  Generally, COBRA must be offered for an HRA.  Under general COBRA rules, a qualified beneficiary who elects COBRA will have access to their unspent account balance and be entitled to HRA accruals that active employees get. In this case, there are no employer contributions for active employees - only balances, which are forfeited upon termination.  Are we required to offer terminated employees the option to continue their HRA coverage by paying a COBRA premium that will in essence fund their account going forward?  This would give them greater rights than the active employees - that doesn't sound right? Help!

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