Are all plans subject to federal COBRA?

• A. Yes, for all employers and plans.
• B. Only private sector plans are subject to COBRA.
• C. Federal policy across all states.
• D. It applies to group health plans of employers with 20+ employees; small-employer plans under 20 may rely on state mini- COBRA.

Answer: (D)

COBRA coverage continues for group health plans based on who sponsors the plan. The federal rule targets plans sponsored by employers with 20 or more employees, meaning those plans must offer the option to continue coverage for a total of 18 to 36 months after a qualifying event. For small employers under 20 employees, federal COBRA doesn’t automatically apply, but many states have “mini-COBRA” laws that require continuation coverage for small-group plans if the state has such a law. Also, some plans are exempt from COBRA entirely, such as most government plans and church plans. So the correct idea is that COBRA applies to group health plans of employers with 20+ employees, while smaller-employer plans may rely on state mini-COBRA if the state has that requirement.