Most COBRA problems are not complicated. They are late. A notice that should have gone out in two weeks went out in six, a claim comes in, and now there is a question about who pays it.
COBRA runs on day counts. Here they are.
Notices you owe
General notice — within 90 days after a participant enrolls in the plan. This is the one employers forget, because it is due at the start of coverage rather than at the end.
Election notice — within 44 days after the qualifying event where the employer is also the plan administrator. Where the plan administrator is a separate entity, the notice is due within 14 days after being notified of the qualifying event.
Notices the employee owes you
For divorce, legal separation, or a child losing dependent status, the qualified beneficiary must notify the plan within 60 days. Your 14-day clock does not start until they do.
This is worth communicating clearly. An employee who tells you about a divorce four months later has usually blown their own window, and that conversation is unpleasant for everyone.
The employee’s decision clock
- Election period: 60 days, running from the later of when coverage ends or when the election notice is provided or mailed.
- First premium payment: 45 days from the date of election.
- Every payment after that: a 30-day grace period after each due date.
The 44 / 60 / 45 sequence is the one to memorize. Notice within 44 days, 60 days to elect, 45 days to pay.
How long coverage lasts
- Termination or reduction in hours: 18 months
- Death of the employee, divorce or legal separation, Medicare entitlement, or loss of dependent status: 36 months
- Disability extension: an additional 11 months, for 29 months total
- Second qualifying event during the initial period: extended to 36 months total
Why COBRA is usually the first thing employers outsource
It runs on statutory deadlines, it is one of the more common sources of employer benefits liability, and it typically lands on whoever in HR has the least time. It is also self-contained — moving it off your plate does not disturb anything else.
A fair number of our clients started with COBRA alone and added the rest later.
Source: U.S. Department of Labor, FAQs on COBRA Continuation Health Coverage for Workers
Verified against primary sources in August 2026. Deadlines and thresholds change — confirm against current IRS and DOL guidance, or call us at (920) 243-4006 and we will check it with you.
This is the work we do.
Benefi administers group benefit plans for employers — including the deadlines above. If you are not certain where your plan stands, that is a short conversation, not a project.