COBRA and Church Plan

[SLuskin]

I had always thought that Church plans were exempt from COBRA. Now I am finding out that they may elect to offer COBRA.

Once a Church offers COBRA, can they ever go back and claim that they are exempt?

Would they be subject to the same penalties for noncompliance if they choose to offer COBRA, but do it improperly?

I have gotten an emergency call from the Executive Director of our Temple on this matter, and I am afraid they may have gotten themselves into some sort of trouble.

Thanks.