Can COBRA participant elect into dental coverage during open enrollment?

[oriecat]

We are now in our open enrollment period. Active employees must take both medical and dental, they are bundled. However for COBRA we unbundled and the COBRA enrollees can take whichever they need. A medical COBRA enrollee asked me today if she can now add dental since it is open enrollment, or since she did not elect COBRA for dental at her initial enrollment, is that now not available to her? I know with COBRA she has to have the same rights as similarly situated non-COBRA participants, but that doesn't really apply here since they all have to have both. Thoughts?