COBRA required for examination only plan?

[Guest Calimayhew]

I have a client that has a group health plan that ONLY provides free medical examinations to eligible employees and retirees (no dependents). When redoing their SPD, I wanted to add COBRA language since the plan seems to fit the definition of IRC 213(d)(1)(A). The administrator said that they've never sent out a COBRA notice and doesn't want to include the info.

Does anyone have any thoughts?

[oriecat]

Sounds like COBRA would apply to me, provided that they are big enough. Did they provide any justification for why they think it doesn't?

[Guest Calimayhew]

Other than, "really? We never heard that before." Sometimes I wonder....