Virta and COBRA

Looking for thoughts on whether the Virta diabetic add on program would be subject to COBRA.  I'm inclined to say no, that it is an independent, non-coordinated benefit (disease-specific, excepted benefit, but wanted to see what everyone else's thoughts are.

Thank you!

I'm not familiar with Virta, but it certainly sounds like a medical expense.  If so, the employer's coverage of the expense creates a group health plan subject to COBRA.  Excepted benefits avoid the HIPAA portability provisions and ACA market reforms--but they don't avoid COBRA.