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I am in my 42nd year and have never seen a fully insured or stop-loss carrier approve an extension of COBRA. Not saying that they have not, just never seen it before. The risk is not worth it to the carrier.

Brian is correct. I work on the carrier side, highly unlikely any fully insured carrier will allow it, and same for any self-funded group.

In theory it can be done, but in reality it generally does not occur for a number of practical reasons: If fully insured, the insurance carrier won't allow it. If self-insured, they likely have stop-loss that won't allow it. ERISA requires the plan be administered pursuant to its written terms. An employer using its ability to interpret plan terms to allow an individual to continue coverage beyond the plan's standard COBRA terms would create a plan precedent that must be applied to other similarly situated individuals. COBRA has inherent adverse selection issues. Even if the employer could get through all those issues (very unlikely), it would simply be quite expensive to expand beyond the required timeframes. These are generally the same reason employers do not allow extensions on election/payment deadlines. More details: https://www.newfront.com/blog/addressing-employee-health-plan-exception-requests-part-x Slide summary: 2024 Newfront COBRA for Employers Guide

And?