Can state mini-COBRA laws apply in addition to federal COBRA?

• A. No
• B. They replace federal COBRA
• C. They may apply in addition to federal COBRA for smaller employers
• D. Only if the employer is government

Answer: (C)

State continuation rules exist to catch what federal COBRA doesn’t reach. Federal COBRA applies to group health plans sponsored by employers with 20 or more employees, giving a right to keep coverage for a limited time after a qualifying event. State mini-COBRA laws step in for smaller employers—often 2 to 19 employees—to extend that same kind of continuation protection. They don’t replace federal COBRA; they run alongside it and can provide additional months of coverage for employees of small employers. If both rules apply, the plan typically must honor the protections offered—often the state rule extends coverage after federal COBRA ends, or offers more generous terms, depending on the state. That’s why the best answer is that state mini-COBRA laws may apply in addition to federal COBRA for smaller employers.