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Mini-COBRA Expansion States

Hope everyone is having a great spring. Just wanted to update on the increase in mini-COBRA state continuation coverage programs going on currently.

Last month Viriginia added a state mini-COBRA program which went into effect in early April, 2009. I found out today that Pennsylvania is also finishing legislation to add a mini-COBRA program. Virginia's program runs 9 months to coincide with the subsidy. I expect Pennsylvania to go 9 or 18 months, again with the first 9 being subject to the subsidy.

For those who are not aware, a part of the ARRA legislation requires state mini-COBRA programs to provide the same 65% subsidy to qualified beneficiaries as the federal COBRA program.

In California, we have a program called "Cal-COBRA" which is the state mini-COBRA program with a special feature not found in other states.

Cal-COBRA applies to groups 2-19 employees which fall below the federal COBRA size. Additionally, Cal-COBRA contains an extension of coverage provision under AB 1401 which can apply to groups of any size, not just 2-19. This was signed into law by Gray Davis when he was still the governor. Under AB 1401, certain groups above 20 are eligible for an extra 18 months on Cal-COBRA after the first 18 months of federal COBRA. Generally, the groups must be fully insured (not self-insured/self-funded) and must be covered by a carrier domiciled in California. Plans outside of California, like self-funded plans, are exempt.

For more information on Cal-COBRA extension and AB 1401, visit this page on my site.

For more information on Cal-COBRA and California mini-COBRA, visit this page on my site.

Before I forget, Happy Cinco de Mayo!


  1. Your website says people living in other states are eligible for the extra Cal-Cobra extension once regular Cobra runs out. Is that accurate? I worked for an employer headquartered in CA. The insurance is Blue Cross of California (Anthem PPO). So, it seems I meet the qualifications of the employer and insurance being domiciled in CA. Yet, I spoke to customer service--and a supervisor of the insurance company and was told that's not true. The extension only applies to CA residents.

  2. I just spoke with Anthem CA and was told that domicile of the employee does not matter for the Cal-COBRA extenstion so long as it is a PPO plan and meets all of the other eligibility criteria.

    I have had clients covered under the extension in Minn and Texas both who worked for CA domiciled employers under Anthem PPO plans.

    The exception would be if the plan is an ASO contract with Anthem (admin services only) which is a self-insured/self-funded arrangement and exempt.

  3. Someone on the initial 18 months of COBRA with Anthem Blue Cross thru a self-funded PPO plan. Her Open Enrollment is November. Can she switch to their HMO plan and be eligible for the CalCOBRA 18 months extension? She is on a large group. Thanks

  4. As long as she switches off of the self-funded plan onto the fully insured plan prior to expiration of COBRA, she should be able to elect the extension.

  5. Hi David. I'm an out-of-state resident recently laid off by a small CA company. Thankfully, they are going to take me back on as an independent contractor, though without benefits. (Unhappy about the change, but very thankful that I will continue to have work.) I was told I could continue my current plan through Cal-Cobra but haven't received the info yet. I got the impression that I would only get 18 months, but it sounds like it should actually be 36, is that right? Since I don't plan to change jobs, what will my options be after that? I'm guessing that Anthem will offer me some sort of conversion plan, but I'm concerned it'll be a lot more expensive (I took antidepressants in the past which I'm worried will make depression a preexisting condition for me). I know there is something called HIPAA which offers some protections, but that won't stop my premium from going way up, will it? Also, does HIPAA apply if I want to change to an insurer in my state or am I pretty much stuck with Anthem in terms of who is obligated to insure me? (I'm obviously quite worried that other insurers would reject my application.) I've heard about getting group coverage through trade associations and other organizations, but don't know how to look for them. Is that even a viable option? Thanks in advance for your help, and for providing the great info!


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