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How is a buyer to treat cobra continuation coverage under the following circumstance:  Seller has former employees who have elected mini-COBRA coverage pre acquisition.  Seller will terminate the benefit plans so Buyer will have the obligation to provide COBRA to all M&A qualified beneficiaries which would include those individuals currently receiving mini-COBRA.  Does Buyer continue to provide coverage for the mini-COBRA period (12 months) even if Buyer is a large employer and not eligible for mini-COBRA or does the COBRA continuation period increase for those already receiving mini-COBRA because Buyer is subject to the federal COBRA regulations?

If you're aware of any  guidance, PLRs, cases, please share.  

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