An association of like employers has a single group health plan. Two employers have over 20 employees. Does this make all the employers enrolled in the plan subject to COBRA, or just the two employers with over 20 employees? The association is not a registered MEWA.

Thank-you,
Brenda

If there is no collective bargaining agreement, each bank is evaluated individually to determine if they are a small employer. So, only the two employers with over 20 employees are subject to COBRA. The others may be subject to state continuation rules though.