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Which Employers Are Subject To COBRA?

11/10/2025

Under the Consolidated Omnibus Budget Reconciliation Act (COBRA), employers have specific legal requirements to provide continuing health insurance coverage to eligible employees and their families after certain qualifying events.

Employers That Must Comply With COBRA Requirements:
  • Private-sector employers with 20 or more employees on more than 50% of typical business days in the previous calendar year (Includes part-time employees counted as a fraction of a full-time employee)
  • State and local government health plans, but not federal employees, as they are covered by other laws
Employee count includes:
  • Full-time employees
  • Part-time employees (counted as a fraction of a full-time equivalent)>/li>
The following organizations are not subject to COBRA:
  • "Small employers" (Employers with fewer than 20 employees on more than 50% of their typical business days in the previous calendar year)
  • Federal government plans (Federal employees are covered by the Federal Employees Health Benefits (FEHB) program, which has its own continuation-of-coverage rules that are similar to, but not governed by, COBRA)
  • Churches and certain church-related organizations (COBRA does not apply to plans sponsored by churches or certain church-affiliated organizations that are exempt under ERISA.)