What triggers the disability extension to 29 months for COBRA?

• A. The plan administrator determines disability
• B. The beneficiary must enroll in Medicare
• C. SSA determines disability and the plan is notified within 60 days of that determination
• D. The employee loses eligibility for the dependent status

Answer: (C)

The trigger is an SSA disability determination with timely notice to the plan. If the Social Security Administration determines that the beneficiary is disabled, COBRA can be extended for 11 more months (for a total of 29 months) as long as the plan is notified of the SSA determination within 60 days of that decision. This makes the SSA ruling the decisive factor, not the plan administrator’s own determination. Enrollment in Medicare or losing dependent status do not initiate the 29-month extension, though Medicare status can align with disability—it isn’t the trigger by itself.