Connecticut COBRA (Health Insurance Continuation) laws & HR compliance analysis

Connecticut COBRA (Health Insurance Continuation): What you need to know

Connecticut healthcare insurance laws include several continuation provisions that duplicate and expand the requirements of the federal Consolidated Omnibus Budget Reconciliation Act (COBRA). The most important provisions provide that certain group healthcare plans include specific requirements for continuation of group coverage or conversion to an individual policy when coverage would otherwise terminate for the specified reasons. The biggest differences from federal COBRA are that Connecticut's requirements apply to all health plans and employers, with no minimum size requirement, and 30 months of continuation is required following a layoff, reduction of hours, leave of absence, or termination of employment.
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The Connecticut law (CT General Statutes Sec. 38a-554(b)(6)) adopts by reference all the qualifying events that trigger the right to continuation coverage provided for by the federal COBRA statute (ERISA Sec. 603) “as amended from time to time.” The maximum coverage periods, the events that allow an early termination of COBRA coverage, and the premiums that may be charged are also adopted by reference to the applicable provisions of COBRA (ERISA Sec. 602).
The Connecticut law also provides specifically for some of the same qualifying events as under federal law. The distinction is that for these events, the circumstances that allow for the early termination of such coverage are not exactly the same as under federal law.
Qualifying events. Covered group healthcare plans must provide employees and their covered dependents the option to continue coverage after a:
• Layoff;
• Reduction of ...

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