Need to offer COBRA?

[Mary C]

We are planning for our annual enrollment. We will be unbundling dental from medical and offering full time employees three options - a DMO, a basic option POS and a high option POS. Since we are unbundling dental, we will also be offering dental only COBRA if someone is only enrolled in dental coverage when an event occurs. Also new this year, we will be offering the basic dental POS option to part time employees. Our question is this - when a full time employee who is enrolled in the DMO or the high option POS decreases hours to part time and loses eligiblity for the DMO or high option POS, does COBRA need to be offered due to the reduction in hours? They will still remain eligible for a dental option, just not the one they are enrolled in.

[Guest jrzgrl]

Yes, you will need to offer the COBRA. It doesn't matter that they will qualify for a different plan; what matters is that they lost eligiblity in their current plan due to a decrease in hours.