COBRA Rules when going from full time to part-time status & Loss of employer subsidy.

[Guest JPotosky]

When an employee goes from subsidy status to non-subsidy status with an employer due to employer rules (commissioned sales person not meeting sales targets to get subsidy), is this a qualifying event that starts the COBRA process? With notice of the loss of subsidy does the employee have 45 days to opt out of the plan if they are paying the full freight from the time the subsidy is lost?