Yes, the 60-day election period (EP) for COBRA continuation coverage may be extended as described in the following examples:

  • Example 1: On March 15, 2020, Nancy loses her employment as well as her group-sponsored health coverage due to COVID-19 and is provided a COBRA election notice from HMAA on March 20, 2020. What is the deadline for Nancy to elect COBRA coverage? Because the loss of Nancy’s employment triggered a COBRA election period and the Outbreak Period is disregarded. Nancy has 60 days from the end of the one-year extension date that the timeline would have started (March 15, 2021), in this case until the deadline (May 14, 2021), to elect COBRA coverage. If elected and premiums are paid, her COBRA coverage will be effective March 15, 2020.
  • Example 2: On January 22, 2020, Norm’s company cuts his hours and he loses eligibility in his group-sponsored health plan. He is provided a COBRA election notice by HMAA on January 27, 2020. What is the deadline for Norm to elect COBRA coverage? Because the loss of Norm’s eligibility triggered a COBRA election period and the Outbreak Period is disregarded, Norm has 27 days* from the end of the Outbreak Period (February 28, 2021), in this case until the deadline (March 27, 2021), to elect COBRA coverage. If elected and premiums are paid, his COBRA coverage will be effective January 22, 2020. *Timeframe calculation: 60 days (Election Period) – 33 days (EP utilized prior to outbreak period) = 27 days (EP remaining).
  • Example 3: On April 1, 2020, Jane loses her employment as well as her group-sponsored health coverage due to COVID-19 and is provided a COBRA election notice by HMAA on April 10, 2020. Jane sends in her election form and first month of COBRA premiums on June 15, 2020 requesting that COBRA coverage become effective July 1st. Can this be accommodated? Because the loss of Jane’s employment triggered a COBRA election period, the Outbreak Period is disregarded. Jane has 60 days from the end of the one-year extension date that the timeline would have started (April 1, 2021), in this case until the deadline (May 31, 2021), to elect COBRA coverage. If elected and premiums are paid, her COBRA coverage will be effective April 1, 2020. No gap in coverage can exist; therefore, Jane’s request for July 1st cannot be accommodated.