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KIP KRAUS
I don't know if this question has been asked before, but when the employer maintains separate medical and dental plans does the issue of Medicare Eligibility come into play with regard to the separate dental plan? In other words can we assume that regardless of a person's Medicare Status(i.e.,covered or eligible for coverage)if the person is age 65 can we refuse to offer COBRA Dental and/or automatically cancel COBRA dental at age 65?

By the way, what is the real answer to not offering any COBRA to an employee who terminates employment at age 65 or older? Do you even have to offer COBRA?
Linda
You should offer COBRA to an employee terminating at or after 65. See 54.4980B-7 Q&A-3. Also, see the discussion of Geissal in the preamble of the regulations, the heading "Qualified Beneficiaries."
KIP KRAUS
Thanks Linda. Actually, since posting this message I have read that section of the Regs. and agree that COBRA should offered.
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