I have a retired employee that qualifies for lifetime medical (at no cost, the same as an active employee) for himself and one eligible dependent. If the retiree would like to keep an additional dependent under his retiree plan he may do so by paying a small monthly premium. This particular retiree has elected to keep the spouse covered and to drop his dependent child. For the child is this an 18-month or 36-month qualifying event? I believe it to be an 18-month event. Also would the premium charged be the small monthly fee that the retiree would be allowed to pay for an additional dependent, or our normal composite rate charged for COBRA? Note: We are a self-insured plan.

If you consider the qualifying event to be the employee's termination of employment (retirement) then the dependent is eligible for 18 months of COBRA. As to who pays that premium and in what amount that is really up to the company. However, you should always be consistent.