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  1. I know that under the FMLA, participants on unpaid FMLA leave have reinstatement rights immediately upon return to active employment, but what about other "terminations for nonpayment" -- For example, if someone is on non-FMLA unpaid leave or if someone's payroll amount is not sufficient to cover the employee share of the premiums? If that individual is terminated from coverage for nonpayment and later begins paying again... (1) Does that person have to pay up all arrearages before being reinstated? Or do they just have to pay going forward (and have their coverage canceled retroactively)? (2) What if that person has a qualified life event during the period he/she is not covered? For example, if that person got married during an unpaid LOA and seeks to be reinstated... would that person be eligible for an election change immediately upon reinstatement? (3) What if that person is terminated while on unpaid LOA and benefits were terminated for nonpayment... ignoring any other legal issues, would that person be entitled to COBRA if they were not participating on the date of termination?
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