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IRS: COBRA Coverage Required as of Date of Divorce, Not Date Coverage Eliminated in Anticipation
Internal Revenue Service [IRS] 
[Official Guidance] Dec. 24, 2002
Rev. Rul. 2002-88. Excerpt: There is no authority under the statute or regulations for requiring a plan to make COBRA continuation coverage available before the date of a qualifying event. Thus, the group health plan in the facts described above has the obligation to make COBRA continuation coverage available to E's former spouse effective as of the date of the divorce for a period of up to 36 months.
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