If an employer offers a vision plan to their employees, must they offer them Cobra for the vision plan? The final regulations do not make this clear, (to my way of thinking any way). I have a client who will be laying off about 5 employees and they asked this question and I wasn't sure if it was at their discretion or if it is now required.

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S. Ostrowski

it is my (non-attorney) opinion, non-core benefits such as vision or dental are not required to be provided under COBRA unless they are part of a indivisible package or the particular state insurance law requires it to be part of a group benefit

I (non-attorney, too) agree with Larry -- it's either core AND non-core or core only unless otherwise required.