COBRA in M&A

[Guest Grumpy456]

Assume neither buyer nor any member of buyer's controlled group sponsors group health coverage. Buyer enters into a transaction with seller such that, under the COBRA rules, buyer is responsible to offer COBRA to M&A qualifying beneficiaries. Is buyer required to purchase group health coverage in order to offer COBRA to M&A qualifying beneficiaries?

Thanks, in advance, for any help.

[Chaz]

Buyer does not need to offer COBRA if it does not offer coverage.