COBRA question. If a QB's coverage ends 12/31 and they enroll in COBRA on 1-29 and pay for the month of January when they turn in their enrollment form when is their next payment due? Do they have 45 days from the date they enroll, can they make partial payments?

Susan -
this isn't as easy to answer as it was to ask. COBRA regs state that you have 45 days from the election date in which to pay the initial premium for coverage. The initial premium covers the period of time from the date you lost active group coverage until you elect coverage. So, the initial premium for coverage from January 1 (the day after you lost your group coverage) until January 29 is due 45 days from the election date or March 15.

Also, the regs state that if a regular monthly premium (for example if we use the dates above - February's premium), falls within the initial premium grace period, payment for that month isn't due to the end of the grace period for the initial premium, or until March 15.

Monthly premiums, beginning with March's, are due and payable on the 1st of each month for that month's coverage. You have 30 days after the firstof the month in which the payment may be postmarked and still be accepted. Good luck.