Continuation cover has no British equivalent, and that is not a gap in this tool
In Britain the question this tool answers does not arise. The NHS provides care whether or not somebody currently has a job, so there is nothing to continue, and no British sibling tool to point to. COBRA is a genuinely American answer to a genuinely American problem: health cover tied to employment, and what happens to it the day that employment changes.
The 20 employee threshold, counted in hours rather than heads
Federal COBRA reaches private-sector employers and unions, and state or local government employers, once they carry at least 20 employees. The Department of Labor puts it precisely, in its FAQs for Employers and Advisers dated September 2025:
COBRA applies to private-sector group health plans offered by employers with at least 20 employees working on more than 50 percent of business days in the previous calendar year.
Part time staff count as a fraction rather than a whole person or nothing at all. DOL's own example: 20 hours against a 40 hour week is half an employee, and 16 hours is four tenths, so a business with nineteen full timers can sit either side of the line depending on those hours alone. Federal government plans and church or church-related plans are excluded outright, whatever their size. Federal employees instead have a similar benefit of their own, temporary continuation of coverage under the Federal Employees Health Benefits Amendments Act of 1988, run through their own agency rather than COBRA.
Why the maximum period is not one number
Most explainers give a single figure for how long continuation cover lasts. DOL's own table gives five, because the length depends on what happened and to whom.
| Qualifying event | Who it covers | Maximum period |
|---|---|---|
| Job loss (other than gross misconduct) or reduced hours | Employee, spouse, dependent child | 18 months |
| Death of the employee | Spouse, dependent child | 36 months |
| Divorce or legal separation | Spouse, dependent child | 36 months |
| Employee becomes entitled to Medicare | Spouse, dependent child | 36 months |
| Dependent child loses eligibility under the plan | Dependent child | 36 months |
Only job loss or reduced hours ever covers the employee themselves. The other four describe something happening to the employee rather than the employee losing their own cover, so it is the spouse or dependent whose cover is at stake, never the employee's.
Who actually counts as a qualified beneficiary
A qualified beneficiary is whoever the plan covered the day before the qualifying event: the employee, their spouse or former spouse, and dependent children. DOL adds three further cases: a retired employee and family if the sponsoring employer later goes bankrupt; a child born to or placed for adoption with the employee during the COBRA period itself; and, where the plan already covers them on the same terms as employees, an agent, independent contractor or director.
Two extensions, and a sequencing rule most calculators skip
An 18 month period can be extended two ways, and CMS is explicit that together they still stop at 36. If the Social Security Administration determines a qualified beneficiary disabled at any point in the first 60 days of COBRA coverage, and the disability lasts through the initial 18 months, every qualified beneficiary in the family can extend to 29 months, not only the disabled person. A second, different qualifying event can then extend a spouse or dependent's cover again to 36 months: someone already on the 29 month track who has a second event moves to 36, not to 40.
A third complication changes which clock is running rather than how long it lasts. Where an employee becomes entitled to Medicare and only later loses their job or has hours cut, a spouse or dependent's cover does not simply run 36 months from the Medicare date or 18 from the job change. CMS takes the later of the two tracks. Reversing the order, an employee already on COBRA who then enrols in Medicare is a different, simpler case.
Under 20 employees is not nothing
An employer below the threshold sits outside federal COBRA altogether, and this tool says so rather than implying there is nothing left to check. Many states run their own continuation law, commonly called mini-COBRA, for smaller employers, and the rules genuinely differ state by state. This deliberately does not attempt a fifty state table: the honest next step is the state insurance commissioner's office.
A qualifying event says why somebody lost their job
The whole calculation runs in the browser. Nothing about an employer's headcount or a qualifying event is sent anywhere or stored, and closing the tab loses it. This works out the federal rule against the figures given, not a determination of your own plan: check the plan's summary plan description, or ask the administrator.
Common questions
Why is there no British version of this tool?
Because the question does not exist in Britain. The NHS provides care whether or not somebody currently has a job, so there is no "continuation of cover" for a British visitor to check, and no British sibling tool to point to. This is written for the United States because that is where health cover is tied to employment in the first place, and where losing that job or having hours cut raises a genuine question with a genuine deadline attached.
How exactly does the 20 employee count work?
The Department of Labor counts employees on more than half the business days of the previous calendar year, and part time staff count as a fraction rather than a whole person or nothing at all: someone working 20 hours against a 40 hour week is half an employee, and 16 hours is four tenths. A business that looks like it has 21 people on the payroll can still sit under the federal floor once the part time hours are converted properly, and a business that looks smaller can sit over it. Source: DOL, FAQs on COBRA Continuation Health Coverage for Employers and Advisers, September 2025.
Why does the maximum period change depending on what happened?
Because the law was written around five different events, not one. Job loss or a reduction in hours gives 18 months and covers the employee as well as their spouse and dependants. Death of the employee, divorce or legal separation, the employee becoming entitled to Medicare, and a dependent child losing eligibility all give 36 months, and all four cover only the spouse or dependent child, never the employee, because none of the four describes the employee losing their own cover.
Who actually counts as a qualified beneficiary?
Whoever the plan covered the day before the qualifying event: the employee, their spouse or former spouse, and dependent children. DOL adds three further cases worth knowing. A retired employee and their family can qualify if the employer sponsoring their retiree plan later goes bankrupt. A child born to or placed for adoption with the employee during the COBRA period itself becomes a qualified beneficiary the moment they join the plan. And, in some plans, an agent, independent contractor or director covered on the same terms as an employee counts too.
What is the disability extension, and when does it apply?
If the Social Security Administration determines a qualified beneficiary disabled at any point in the first 60 days of COBRA coverage, and the disability continues through the initial 18 month period, every qualified beneficiary in that family can extend their cover to 29 months, not only the disabled person. The plan generally has to be told of the SSA determination within 60 days of it, and before the 18 months run out.
Can a disability extension and a second qualifying event both apply?
Both can apply to the same spouse or dependent, but CMS is explicit that the total never runs past 36 months. Someone already on the 29 month disability track who then has a second qualifying event, such as the employee's death or a divorce, moves to 36 months, not to 40 or 47. The employee's own cover is never affected by a second qualifying event, because none of the four second-event types, death, divorce, Medicare entitlement or a dependent losing status, can happen to the covered employee themselves.
How quickly do I have to elect, pay, and be told about it?
A qualified beneficiary generally has 60 days to elect COBRA, counted from whichever is later: the date cover would otherwise end, or the date the election notice arrives. Electing is not the same as paying: the first payment is due within 45 days of electing, and every payment after that carries a 30 day grace period. On the employer's side, an employer generally has 30 days to tell the plan administrator about a death, a termination, a reduction in hours or a Medicare entitlement that costs a dependent their cover, the plan administrator then has 14 days to send the election notice, and a beneficiary reporting their own divorce or a child's loss of dependent status has 60 days to do it. Premiums are capped at 102 percent of the plan's own combined cost, rising to 150 percent for a disabled beneficiary during a disability extension.
What happens if the employer has fewer than 20 employees?
Federal COBRA does not apply at all, and it is worth being plain about that rather than implying there is nothing left to check. Many states run their own continuation law, usually called mini-COBRA, with their own size threshold, duration and cost rules. They vary enough state by state that a single figure here would be a guess dressed up as a national answer, so the honest next step is the state insurance commissioner's office rather than a fifty state table this tool does not attempt.