Must dental plans be continued under COBRA?

As an employer, you offer a number of group health plans, including dental plans, to your employees. Employees in one of your departments are subject to an upcoming termination. Do you have to offer them COBRA coverage for the dental plans, or just the health plans?

The employees would have to be offered COBRA coverage for all of your group health plans, since COBRA covers all such plans, including dental and vision plans. COBRA coverage must be offered for your dental plans in the same way that it is offered for any other health plan. Beneficiaries must be allowed to continue with the same dental coverage in which they were enrolled on the day before a COBRA qualifying event, such as the pending termination.

Coverage options must be same as those offered to active employees. Keep in mind that if the beneficiaries have the option to elect coverage separately under separate health, vision, and dental plans, they must be given the opportunity to continue coverage for any or all of the three types of plans. If, instead, they have to opt into the group plans as a single package, then they can continue under COBRA only with the entire package.

Furthermore, at either open enrollment or HIPAA special enrollment periods, the COBRA beneficiaries must be allowed to change their coverage elections in the same way that active employees do.