What is the difference between federal COBRA and state mini-COBRA?

• A. Federal COBRA applies to large employers; mini-COBRA applies to private plans via state.
• B. Federal COBRA applies to large employers (20+ employees) and many private plans; mini-COBRA is state continuation for small employers and may have different rules and durations.
• C. They are identical in coverage and duration.
• D. Mini-COBRA only applies to international plans.

Answer: (B)

The key idea is that COBRA coverage is split between a federal baseline and state-specific extensions. Federal COBRA covers group health plans offered by employers with 20 or more employees, plus many private plans that fall under federal rules. State “mini-COBRA” laws step in for smaller employers, typically those with 2 to 19 employees, and they can also cover plans or situations not fully dictated by federal rules. Because mini-COBRA is state-based, the exact details—who must offer it, which plans are eligible, how long the continuation lasts, and how premiums work—can vary from one state to another. So while federal COBRA provides a uniform framework for larger employers, state mini-COBRA adds a separate continuation path for small employers with rules and durations that may differ by state. Federal continuation is commonly about 18 months (with possible extensions), and state mini-COBRA durations and requirements can differ, reflecting the state-specific approach.