COBRA Continuation of Health Coverage

Mini-COBRA Continuation of Coverage Benefits

The Massachusetts small group continuation of coverage law (Mini-COBRA) requires small group carriers to provide for the continuation of health benefits to employees of small businesses with 2-19 employees. Mini-COBRA allows employees and their family members to continue coverage on their small group health benefit plan and pay group rates for certain time periods under circumstances where they previously would have lost coverage.

While COBRA and Mini-COBRA are similar, they are not identical and do contain differences. Some differences include:

1. COBRA is a federal law and is not enforced by the Division of Insurance.  Mini-COBRA is a state law and is enforced by the Division of Insurance.
2. COBRA generally applies to group health plans offered by employers with 20 or more employees. Mini-COBRA  applies to small group health benefit plans issued to employers with 2-19 employees.
3. COBRA applies to self-funded plans and group health plans offered by employers with 20 or more employees. Mini-COBRA does not apply to self-funded plans.

Qualified Beneficiaries and Qualifying Events under Mini-COBRA

Mini-COBRA benefits must be provided to Qualified Beneficiaries upon the occurrence of a Qualifying Event. Qualified Beneficiaries are generally individuals who are covered under a small group health benefit plan on the day before the Qualifying Event. Qualified Beneficiaries can be:

1. An employee.
2. The spouse of an employee.
3. The dependent child of an employee.

Qualifying Events are events which would cause a Qualified Beneficiary to lose health coverage if Mini-COBRA benefits were not available. The type of Qualifying Event will determine: (1) who is eligible for MINI-COBRA and (2) the length of time that the benefits must be offered.

Massachusetts law requires employees of small groups (2-19 employees) be offered Massachusetts Continuation of Coverage (COC), the health insurance carriers delegates this obligation to small employers.  Group acknowledges that it is responsible for administering COBRA/COC, including without limitation, providing all required notices.

For more information on Mini-COBRA, please review the MiniCobra Continuation of Coverage Benefits Guide from Mass.gov.

Forms and Documents for Employers