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18 / 29 / 36 — three buckets to memorize

COBRA Continuation Coverage

20+

Employees

COBRA threshold (not 50)

18 / 29 / 36

Months

Three coverage durations

102%

Premium Cap

Full cost + 2% admin fee

match the event to the bucket

The Three Coverage Buckets

Each qualifying event maps to one of three durations. Memorize the events, the months will follow.

18 months

2 events
  • Voluntary or involuntary termination (not gross misconduct)
  • Reduction in hours

29 months

1 event
  • SSA-determined disability within 60 days of COBRA event

36 months

4 events
  • Death of covered employee
  • Divorce or legal separation
  • Dependent child aging out
  • Employee becoming Medicare-eligible

The Notice Cascade

Employer

30 days

Notify plan administrator (termination, hours, death, Medicare)

Qualified Beneficiary

60 days

Notify plan administrator (divorce, separation, age-out)

Plan Administrator

14 days

Provide election notice to QB

Qualified Beneficiary

60 days

Elect coverage

Exam Traps

COBRA threshold is 20, not 50

Different from FMLA (50). Frequently confused. Employers with 20+ employees on a typical business day are subject.

Gross misconduct cuts off COBRA

Standard termination triggers COBRA. Termination for gross misconduct does not. The exam loves this distinction.

102% is the MAX, not the minimum

Full premium plus 2% administrative fee. Employer can charge less. Cannot charge more — except 150% during the 11-month disability extension.

Spouses and dependents can elect independently

Each qualified beneficiary has their own election right. Employee declining does not bind spouse or dependents.

Misconduct cuts COBRA

Gross misconduct termination disqualifies the employee from COBRA. Mere termination does not.

Three buckets

18 for hours and termination. 29 for SSA-disability. 36 for death, divorce, age-out, Medicare. Memorize the buckets.

1
Furnished apartment with subsidized rent

Your employers group health plan. The company covers most of the cost while you live there.

2
Leaving the company

You can sublet the apartment from yourself. COBRA makes this possible — but you pay the full rent now plus 2%.

3
Standard termination = 18 months

Sublet for 18 months at 102% of full premium. Same goes for hours reductions.

4
Disability ruling = 29 months

If SSA says you are disabled, sublet stretches to 29 months. Last 11 can cost up to 150%.

5
Family event = 36 months

Spouse loses coverage from divorce, death, dependent age-out, or employee Medicare entitlement. 36 months at 102%.

6
60-day windows

Plan administrator has 14 days to send election notice. You have 60 days to elect. Miss the window, no sublet.

18 hours/term. 29 disability. 36 family event. 102% the cap. 60 days to elect.
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Reviewed by Sarah L., PrepSolution Content Editor, HR
Sources verified against HRCI 2026 standards
Updated May 2026