Reference · Deadlines
US COBRA notice, election and premium deadlines after job-based coverage ends
A person eligible for federal COBRA generally has at least 60 days to elect continuation coverage, measured from the later of losing coverage or receiving the election notice. The first premium cannot be required before 45 days after election. Later premium due dates have a grace period of at least 30 days.
Sources checked
- Notify the planThe employer usually reports the job-related qualifying event. A beneficiary may have to report other qualifying events.
- Receive the election noticeCheck when job-based coverage ends and when the plan sent or provided the election notice.
- Elect by the later-date ruleThe federal election period lasts at least 60 days from the later of loss of coverage or notice.
- Pay the first premiumThe first payment cannot be due earlier than 45 days after the election.
- Track later premiumsThe plan sets later due dates, subject to at least a 30-day grace period.
The employer and plan have notice duties. A beneficiary’s election and premium periods use their own start dates.
The election date can be later than 60 days from the job event
The federal election period ends no earlier than 60 days after the later of two dates, the date coverage terminates because of the qualifying event or the date the beneficiary receives notice of the election right. If coverage remains in place through the end of a month, use the actual coverage loss date in that comparison. Source 2 Source 5
Check who reports the qualifying event
For covered events such as termination or reduction in hours, the employer ordinarily notifies the administrator. A divorce, legal separation or loss of dependent status generally requires the employee or qualified beneficiary to give notice under the plan’s procedures. A plan that uses a separate administrator ordinarily has 14 days from receipt of the required notice to provide the election notice. Source 1 Source 5
The first premium may cover prior months
The first payment period begins after the beneficiary elects coverage. If the election comes after job-based coverage ended, the first payment can cover several months back to the loss of coverage. Ask the plan for the full first amount and keep confirmation of the election and payment dates. Source 3 Source 4
Record each later due date and its grace period
After the first premium, the plan sets the dates for later payments. Federal law treats a later premium as timely if paid within 30 days after its due date, or a longer period the plan provides. Keep the payment instructions with the notice because failure to pay on time can end continuation coverage. Source 3 Source 4