How does COBRA interact with ERISA?

• A. COBRA rights are not connected to ERISA.
• B. ERISA overrides COBRA and eliminates it.
• C. Most plans are not governed by ERISA; COBRA is separate.
• D. Most employer group health plans subject to COBRA are governed by ERISA; COBRA rights are fiduciary duties under ERISA.

Answer: (D)

The main idea is that COBRA continuation coverage is carried out within the ERISA framework for most employer-sponsored health plans. When a plan is subject to ERISA, it is administered by a plan fiduciary who has duties to manage benefits and run the plan in the participants’ best interests. Those fiduciary duties extend to administering COBRA rights: providing the required COBRA notices, overseeing the election process, handling premium payments, and ensuring the continuation coverage terms in line with both COBRA and the plan’s ERISA terms. In this setup, COBRA is not a separate, standalone rule; it operates through ERISA-governed plans, giving participants a federally mandated way to maintain coverage after qualifying events while the plan remains governed by ERISA’s fiduciary duties. It’s worth noting that a minority of plans—such as some government or church plans—aren’t ERISA-governed, in which case COBRA’s administration can differ, but for the typical private-sector employer plan, COBRA rights are administered as part of ERISA fiduciary duties.