Michigan Conversion Coverage and Continuation for Group Health Plans
Federal COBRA covers employers with 20 or more employees. Michigan has no mini-COBRA law, so for smaller Michigan employers the main state rule is conversion coverage on certain plans.
Michigan does not have a mini-COBRA law that extends employer coverage for insured plans, so this guide explains what the law does provide instead.
Where Michigan Law Stands
Michigan’s rule is conversion, not continuation.
No mini-COBRA. Michigan has no mini-COBRA statute like those in other states. An employer under 20 employees therefore has no state continuation law to fall back on, though the plan’s own terms and the carrier’s certificate should still be checked.
What the Department of Labor says. State continuation laws exist in many states, apply to insured plans and may cover employers with fewer than 20 employees. The Department points people to the state insurance commissioner.
Federal COBRA. Federal COBRA applies unless all employers maintaining the plan normally employed fewer than 20 employees on a typical business day in the preceding year.
Conversion Coverage Under MCL 550.1410a
The Nonprofit Health Care Corporation Reform Act gives members a right to convert.
Who qualifies. A subscriber continuously covered for at least three months, along with a covered spouse and dependents.
The triggers. The group certificate is discontinued, the subscriber loses the job other than for gross misconduct, the subscriber dies, or a family member loses qualifying status.
Timing and notice. Conversion coverage is effective immediately on termination. The subscriber must notify the insurer within 30 days, and the certificate holder must give written notice within 14 days of a discontinuance or job loss.
Cost and protections. The premium is based on the conversion pool’s experience, age, risk class and coverage type, and the individual’s own claims cannot be used. No evidence of insurability may be required, and no new pre-existing condition exclusion applies.
What the Section Does Not Cover
It reaches health care corporations, not every insurer or plan.
Which carriers. The section reaches nonprofit health care corporations. We did not confirm an equivalent for commercial insurers or HMOs.
Exclusions. Conversion is not available for people with similar other coverage, Medicare, nonpayment of contributions, replacement by other group coverage or fraud.
Self-funded plans. The text is silent on self-funded plans, and state insurance laws generally do not reach them.
A 12-Employee Michigan Employer
Smaller than 20 means federal COBRA does not apply.
The facts. A 12-employee company has a Blue Cross group plan. An employee leaves in good standing and has been covered for two years.
The result. Federal COBRA does not apply. The employee may have conversion rights under the certificate, so the company should give written notice within 14 days and the employee must act within 30.
The takeaway. Check the certificate, give the notice on time and confirm the rights with the carrier.
Related Rules and Sources
Where to look for the controlling text.
State Continuation and Mini-COBRA
How other states handle it.
Self-Funded or Insured
Which law applies to your plan.
COBRA Notice Deadlines
The federal notice clocks.
MCL 550.1410a, conversion coverage · 26 U.S.C. 4980B, COBRA · Department of Labor, COBRA consumer FAQ
We confirm the rights before you tell the employee.
We read the certificate with you, confirm what the carrier provides and check the notice before it goes out.
Related pages.
State Continuation and Mini-COBRA
State laws for smaller employers.
COBRA Continuation Coverage Law
The federal rules.
COBRA Notice Deadlines
The 30 and 14 day clocks.
Self-Funded or Insured
Which law applies.
How Much COBRA Costs
The 102 percent premium.
COBRA and Medicare
The Medicare interaction.
Questions that come up.
Short answers to the questions we hear most. Each links to the full page.
Does Michigan have a mini-COBRA law?
No. Michigan has no mini-COBRA law. It does provide conversion coverage on certain plans.
What is conversion coverage?
A right to buy individual coverage when group coverage ends, without proving insurability.
Do employers under 20 employees owe COBRA?
Not under federal law, and Michigan has no mini-COBRA law to take its place.
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