What Is a COBRA Qualifying Event?

9/13/2026

A COBRA qualifying event is an event that would cause a covered employee, spouse or dependent child to lose group health plan coverage. There are seven: the employee's termination (other than for gross misconduct), a reduction in the employee's hours, the employee's death, divorce or legal separation, the employee becoming entitled to Medicare, a child ceasing to be a dependent, and, for retirees, an employer's bankruptcy. The event only counts if it actually causes a loss of coverage, and the event itself decides who becomes a qualified beneficiary and for how long.

The Two-Part Test

An event is a qualifying event only when both parts are met:

It is one of the events listed in the statute. An event not on the list, such as a plan amendment that raises employee contributions for everyone, does not create COBRA rights even if someone drops coverage because of it.
It causes a loss of coverage. "Loss of coverage" includes ceasing to be covered under the same terms as immediately before the event, such as a spouse remaining enrolled but now required to pay a higher premium because of the event. If a listed event causes no change at all, there is no qualifying event, although a later loss of coverage caused by that same event can still trigger COBRA.

The second part explains a common surprise. An employee on single coverage who divorces has no qualifying event for the former spouse, because the spouse was never covered and has nothing to lose.

Qualifying Events for the Employee

Termination of employment

Voluntary resignation, layoff, discharge and retirement all qualify, as long as coverage ends as a result. The only exclusion is termination for gross misconduct. The statute does not define it, courts read it narrowly, and ordinary poor performance or policy violations generally do not meet it. Denying COBRA on this ground is a legal judgment that should go through counsel, not a box ticked on an exit form.

Reduction in hours

This is the qualifying event employers miss most often, because the employee is still on payroll. It includes moving from full-time to part-time below the eligibility threshold, an unpaid leave of absence after which the plan stops coverage, a temporary layoff, and a strike or lockout. If the change ends eligibility under the plan's terms, it is a qualifying event, even if the employee expects to return.

FMLA leave is a special case. Taking FMLA leave is not itself a qualifying event, because the employer must maintain group health coverage during it. A qualifying event generally occurs on the last day of FMLA leave if the employee does not return to work and would otherwise lose coverage.

Qualifying Events for a Spouse or Dependent Child

A covered spouse and covered dependent children become qualified beneficiaries when the employee's termination or reduction in hours causes them to lose coverage. They also have qualifying events of their own:

Death of the covered employee.
Divorce or legal separation from the covered employee. An employee who drops a spouse from coverage in anticipation of a divorce does not defeat the spouse's rights; the later divorce is still treated as a qualifying event.
The employee becoming entitled to Medicare, where that entitlement causes the spouse or dependents to lose coverage. Because of Medicare Secondary Payer rules, this is uncommon for active employees at employers of 20 or more.
A child ceasing to be a dependent under the plan's terms, most often by reaching the plan's age limit.

Employer Bankruptcy

For retiree health coverage, a substantial elimination of coverage within one year before or after an employer's Chapter 11 bankruptcy filing can be a qualifying event for covered retirees, their spouses and dependents. Most HR teams will never see this one, but it matters for employers with retiree medical plans.

Who Becomes a Qualified Beneficiary

A qualified beneficiary is someone covered under the plan on the day before the qualifying event who loses coverage because of it. That includes the employee (for termination and reduction in hours), the covered spouse and covered dependent children. A child born to or placed for adoption with the covered employee during a continuation period is also a qualified beneficiary.

Each qualified beneficiary has an independent right to elect, which is why the election notice has to reach the spouse and children, not only the employee.

Why the Type of Event Matters

The event type sets two things: who is responsible for giving notice, and the maximum coverage period.

The employer must notify the plan administrator of termination, reduction in hours, death and Medicare entitlement. The employee or beneficiary must report divorce, legal separation and loss of dependent status. The full deadline sequence is in our post on COBRA notice deadlines.
Termination and reduction in hours support up to 18 months; the other events support up to 36 months. Extensions and early endings are covered in how long COBRA coverage lasts.

What Is Not a Qualifying Event

A Social Security disability determination can extend an existing 18-month period to 29 months, but it does not start COBRA on its own.
An employee voluntarily dropping coverage at open enrollment.
Taking FMLA leave while coverage is maintained.
Continued coverage itself. Where an employer keeps a departing employee on the plan for a severance period, COBRA rights attach when that coverage actually ends, and the plan document determines whether the continuation period runs from the termination or from the later loss of coverage.
Termination for gross misconduct, if it genuinely meets that standard.

Building Event Capture Into Your Process

Every qualifying event the employer knows about should generate a record the same day: who, what event, the date coverage ends and who is covered. Give reductions in hours and unpaid leaves their own trigger in HRIS or payroll rather than relying on the termination checklist, and remind employees each year that they must report divorce and dependent status changes. Our COBRA compliance checklist shows where this fits in the wider process, and employer requirements under COBRA covers coverage thresholds and notice obligations.

Frequently Asked Questions

Is quitting a COBRA qualifying event?

Yes. Termination of employment qualifies whether it is voluntary or involuntary, as long as it causes a loss of coverage.

Is a reduction in hours a qualifying event if the employee stays employed?

Yes, if the reduction causes the employee to lose eligibility under the plan. Continued employment does not matter.

Is turning 26 a qualifying event?

Losing dependent status under the plan's terms is a qualifying event. For most plans that happens at the plan's age limit, and the employee or child must notify the plan within 60 days.

Can an employer deny COBRA to an employee fired for misconduct?

Only for gross misconduct, which is narrowly construed. Get legal advice before relying on it.

Is the employee's own disability a qualifying event?

No. Disability can extend an existing continuation period, but it is not a qualifying event by itself.