Is disability a COBRA qualifying event?

An employee has been on work-related disability for six months and the company now wants to send him a COBRA letter because he is no longer considered working full-time for 40 hours per week, which would make him ineligible for medical benefits. He is not terminated as an employee and may come back to work. The payroll administrator has a box to check on their form that the qualifying event that resulted in a loss of coverage eligibility is disability. On a COBRA letter sent to an employee, can the reason for COBRA state that the qualifying event is due to a disability?

Disability by itself is not a COBRA qualifying event. For an employee, the only COBRA qualifying events are termination of employment or reduction in hours that would result in the employee losing health care coverage, in which case the employee can get up to 18 months of COBRA.

In this case, the employee would lose health coverage due to a reduction in hours, and the plan must offer COBRA according to plan provisions and COBRA requirements. The employee could be entitled to COBRA continuation for up to a total of 29 months, if the employee receives a Social Security disability determination within the 18 months of COBRA, and the employee provides a notice of that determination within 60 days of the determination and within the 18 months of COBRA, and the individual is deemed to have been SSA disabled during the first 60 days of COBRA.