COBRA notices have specific deadlines. Missing one is not a technicality.
Continuation coverage is mostly paperwork delivered on time. The penalties for getting it wrong land on the employer rather than on whoever actually missed the date, and the most expensive failures are the quiet ones — a notice never sent to someone who later needed coverage.
Five deadlines, in order, every time.
These are the counts the regulations actually impose. They are not difficult. They are simply unforgiving, and they start running whether or not anyone noticed the event.
Employer to administrator
Thirty days from the qualifying event. If your payroll or benefits platform defaults a termination to voluntary and nobody corrects it, this clock is already running against a record that is wrong.
Administrator to qualified beneficiary
Fourteen days to issue the election notice. Sent to the last known address, documented, and provable — because proof of mailing is the defense if it is ever questioned.
Election, payment and grace
Sixty days to elect, forty-five days to make the first payment once elected, and a thirty-day grace period on payments thereafter. Coverage is retroactive, which is why a beneficiary who elects late still has to be handled precisely.
Twenty employees is the federal line, and the state line is somewhere else.
Size and geography both decide what you owe, and the two answers rarely match.
Michigan, specifically
Federal COBRA applies to employers with twenty or more employees. Michigan has no state mini-COBRA, so a Michigan employer under twenty has no continuation obligation at all — federal or state. That is genuinely unusual, and it is worth knowing before you promise an exiting employee something the plan cannot deliver.
Other states
Several states extend continuation rights to smaller groups, with their own durations and mechanics. If you employ people outside Michigan, their state’s rule can apply to them while nothing applies to your Michigan staff.
Which events count
Termination and reduction of hours are the obvious ones. Divorce, a dependent aging out and an employee becoming entitled to Medicare also trigger rights — and those depend on someone telling you, which is why the initial general notice matters.
Plans beyond medical
Dental, vision and most health FSAs and HRAs carry continuation rights too. Employers routinely offer COBRA on medical alone and never notice the omission.
Administered, not outsourced into a gap.
Notices and elections
General notices at enrollment, election notices on the event, and a record of both. The documentation is the product.
Premium billing and collection
Invoicing, collection and termination for non-payment handled on the calendar, so a lapsed payment does not become a coverage dispute months later. Direct billing for retirees and other continuants runs the same way.
The termination reason, corrected
Because no payroll integration passes the reason for a separation across the wire, we confirm it with a person before the notice goes out. That single field decides eligibility.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Bloomfield Hills, MI 48304
248.370.8853
719.425.2649
281.404.5670
Cookies on this site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential — needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics — tell us which pages get read, so we know what is worth writing more of.
- Advertising — set by third parties such as ad and social platforms to measure and target campaigns.