Defining 90-day Qualification Period for LTD

[Guest CSF]

The Long Term Disability policy for our association requires a 90-day non-working period to qualify for the benefit. We are a small association and come under the DC mini-COBRA continuation. The person in the DC office said that the 90-day period qualifies as a reduction in hours and therefore an Involuntary Termination. Our HR person insists it is a Voluntary Termination because in involves a disability. Who can I go to for a valid determination? It means a difference of 3 months or 15 months of health coverage.