Beyond COBRA: state laws add complexity to continuation coverage 

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.