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Beyond COBRA: state laws add complexity to continuation coverage 

  • Contributor
    Rich Glass
    Principal, Law & Policy Group, Marsh People and Investments
  • Contributor
    Leena Bhakta
    Partner, Marsh People and Investments

November 12, 2024

 

The Consolidated Omnibus Budget Reconciliation Act (COBRA) has endured for decades. Less familiar is COBRA’s sidekick: state continuation laws. These laws (often referred to as “mini-COBRA” laws), fill in COBRA’s gaps, particularly for small employers offering fully insured group health plans as well as fully-insured large-employer group health plans (often referred to as “post-COBRA” laws), where coverage is required beyond COBRA’s normal time frames. This GRIST summarizes the major aspects of state continuation requirements — including a comparison and interaction with COBRA rules and useful tables encapsulating applicable laws in each state. Of particular importance are four states that have enacted post-COBRA laws applying to all fully-insured group health insurance policies in those states.

Generally, state continuation laws apply only to fully insured plans subject to a particular state’s law.

Download the 24-page print-friendly PDF for more information.

About the author(s)
Rich Glass
Leena Bhakta
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