Which Employees Are Counted for Purposes of COBRA’s Small Employer Exception?

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Which Employees Are Counted for Purposes of COBRA’s Small Employer Exception?
Thomson Reuters / EBIA

[Guidance Overview]
Nov. 20, 2025

"Count all employees, not just plan participants.... Count only common-law employees.... Count part-time employees.... Count employees of related entities (and successors).... Count employees and related entities outside the United States. " MORE >>

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