Is the 18 month COBRA term a maximum period of coverage for an employee from any one employer under all circumstances or is it the maximum term associated with a discrete qualifying event? An employee went on an unapid leave and started COBRA for one month. He returned to work and one month later took a permanent work force reduction offer. Does he get a new 18 month term? Or is the 18 month term for reduced hours or termination reduced by the earlier one month of COBRA coverage leaving 17 months from the second event, the termination? Does the length of the return to active status make a difference? Thank you for your thoughts.

I believe he would be eligible for a new 18 month period because he returned to work and therefore went off COBRA and it's another qualifying event.