Which employers must offer COBRA?

COBRA generally applies to private-sector employers with 20 or more employees that sponsor group health plans, plus state and local governments. Many states have mini-COBRA laws extending similar rights to smaller employers. Coverage obligations depend on plan type and headcount.

How long does COBRA coverage last?

Continuation coverage typically lasts up to 18 months for events like termination or reduced hours, and up to 36 months for certain events such as divorce or loss of dependent status. Disability can extend the 18-month period. The maximum depends on the qualifying event.

What are the key COBRA notice deadlines?

The plan administrator generally must send the election notice within 14 days of being notified of a qualifying event, and employers must notify the administrator within 30 days of certain events. Qualified beneficiaries then have 60 days to elect coverage. Missing these windows creates significant liability.

Free COBRA Administration Checklist Checklist

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COBRA Administration Checklist

Employer Name:

Plan Administrator:

Group Health Plan Name:

Plan Year:

Coverage and Notice Obligations

Determine whether the employer is subject to federal COBRA requirementsIdentify all group health plans subject to COBRA continuationProvide the COBRA general notice to all covered employees upon enrollmentNotify the plan administrator of qualifying events within 30 daysEnsure qualified beneficiaries notify the plan of certain qualifying eventsIdentify all qualifying events triggering COBRA rights

Election Process

Send the COBRA election notice within 14 days of receiving notice of a qualifying eventAllow the full 60-day election period for qualified beneficiariesProcess COBRA elections and retroactive coverage upon timely electionHandle waiver and revocation of COBRA election within the election periodDetermine the correct maximum coverage period based on the qualifying event

Premiums and Payments

Set the COBRA premium at no more than 102 percent of the applicable premiumAllow the 45-day initial premium payment grace periodApply the 30-day grace period for subsequent monthly premiumsProcess premium payments and maintain accurate payment recordsSend premium shortfall notices for insignificant underpayments

Coverage Duration and Termination

Terminate COBRA coverage only for permitted reasonsProvide notice of early termination of COBRA coverageProcess the disability extension for Social Security disabled beneficiariesHandle second qualifying events extending the 18-month period to 36 months

Recordkeeping and Program Oversight

Maintain COBRA administration records for at least six yearsCoordinate with third-party administrators for accurate and timely COBRA processingUnderstand excise tax penalties for COBRA noncomplianceReview COBRA procedures when plan terms or carriers changeAudit COBRA processes annually for compliance

The complete guide

Everything you need to know

01What Is the COBRA Administration Checklist?

COBRA lets employees and dependents continue group health coverage after qualifying events like termination or reduced hours. This checklist covers the notices employers and plan administrators must send, the strict timelines for each, election and payment tracking, and coverage duration rules. It helps benefits teams administer continuation coverage accurately and prove that required notices were delivered on time.

02Why Use a COBRA Administration Checklist

COBRA is deadline-driven and notice-heavy, and missed or late notices expose employers to statutory penalties, excise taxes, and lawsuits, especially when a former employee incurs claims during a coverage gap. Because the rules apply to employers with 20 or more employees and involve several distinct notices, tracking is essential. This checklist ties each qualifying event to its required notice and timeframe so nothing is missed.

03How to Use This COBRA Administration Checklist

Provide the initial general notice when coverage begins. When a qualifying event occurs, confirm the event date, then send the election notice within the required window. Track the qualified beneficiary's election period, premium payments, and grace periods, and monitor the maximum coverage duration. Send termination notices when coverage ends. Keep dated proof of every notice and tick each step for each beneficiary.

COBRA Administration Checklist

COBRA Administration Checklist

Coverage and Notice Obligations

Election Process

Premiums and Payments

Coverage Duration and Termination

Recordkeeping and Program Oversight

Everything you need to know

01What Is the COBRA Administration Checklist?

02Why Use a COBRA Administration Checklist

03How to Use This COBRA Administration Checklist

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