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Rev. Rul. 2004-22: Medicare Entitlement of Covered Employee Often Not a Second Qualifying Event (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Feb. 13, 2004
5 pages. Excerpt: HOLDING: The Medicare entitlement of a covered employee is not a second qualifying event for a qualified beneficiary unless the Medicare entitlement would have resulted (if COBRA continuation coverage, including COBRA continuation coverage due to the first qualifying event, is disregarded) in a loss of coverage for the qualified beneficiary under the group health plan that is providing the COBRA continuation coverage.
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