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What if multiple qualifying events occur during my COBRA continuation period?

If a second qualifying event occurs during an 18 or 29 month COBRA continuation period, the continuation period for the employee’s covered spouse and/or dependent children is extended until 36 months after the first qualifying event.

Example: Joanne' s husband Bob, who holds the family’s medical benefits through his employment, loses his job in August and the family begins to pay for COBRA coverage that will continue for 18 months. In December, Joanne and Bob become legally separated. Joanne and any of her dependent children are entitled to extend their COBRA coverage an additional 18 months (up to a total of 36 months from the first qualifying event—the job loss) as a result of this second qualifying event.

Example: In May, Jane reduces her hours at work due to her treatment. As such, she no longer qualifies for her employer’s health plan and elects to begin COBRA coverage. Two months later Jane quits altogether. The law views these two events as a variation of a single qualifying event, and consequently does not entitle Jane to extend the original 18 months that began after the May reduction in hours for an additional 18 months.

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