Employees retiring prior to age 65 can continue their healthcare coverage until they are Medicare eligible. Is the COBRA "event" the date they retire, or the Medicare eligibility date? If the event is the retirement date, would the Medicare eligibility date be considered a second qualifying event?

It is not clear exactly what is involved in this program. Does the employer simply provide "access" to continued health coverage (i.e., the employee pays for the cost of continued coverage, but may do so until he or she becomes eligible for Medicare) or does the employer provide coverage (i.e., no employee cost) for all retirees who retire prior to the time they become eligible for Medicare?

The retirement or termination of employment is of course a qualifying event; however, if the retiree can continue existing coverage as a Retiree and that status allows the Retiree to carry the employer coverage until age 65, Medicare eligibility, then I would say that the COBRA qualifying event would be the loss of coverage as a Retiree at 65. This is the way we handle Retirees in our health plan.