COBRA & SLOB's

[alexa]

1 of our subsidiarys ceased operations late last year and they terminated fully insured medical coverage. They did not offer COBRA since the group health plan ceased to exist.

The sub is part of our controlled group but all of our subs operate as separate lines of business.

Were we required to offer COBRA coverage under 1 of our other subs health plans or are we exempt since SLOB under 414® of IRC?

[jeanine]

This is too tough of an issue to address in this forum. We've had similar companies with the same issue and had them get a legal opinion from an atty with COBRA experience. All I can tell you is that based on their corporate set-up, they had to offer COBRA. You need a detailed analysis as to the legal implications of your corporate design and COBRA responsibilities.