Michigan Compliance

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.

Back to state continuation and mini-COBRA

The Detail

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

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.

Limits

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.

Worked Scenario

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.

What the Rules Connect To

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

Where We Help

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.

Talk to us about continuation coverage

Keep Reading

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 We Get

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.

Ready? Send us your renewal, or talk it through with someone first. No cost, no obligation.

Talk to an Expert

General information, not legal or tax advice. Plan-specific questions belong with the plan documents, the carrier and counsel.

Let’s Get to Work

Send us your renewal.

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What to send

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.

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