State RegulationsMI specificDifficulty 2/5
A Michigan employee of a firm with 12 employees is terminated and asks about continuation of health coverage. Based on the federal COBRA thresholds described in DIFS consumer guidance, what is the situation?
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Answer & full 3-part explanation (select an option above, or peek)
Why A is correct
DIFS consumer guidance places federal COBRA at employers with 20 or more employees, so a 12-employee firm is outside federal COBRA's scope. Michigan law does not extend COBRA to smaller groups with a verified duration; instead, the special enrollment rights of M.C.L. 500.3708 can matter when an employee loses other coverage. The employee's options therefore rest on other law or plan terms rather than federal COBRA.
Why the other options are wrong
- B) The 18-month federal COBRA duration never applies to a 12-employee firm outside COBRA's 20-employee threshold.
- C) Michigan has not extended federal COBRA to every employer size; DIFS guidance ties COBRA to the 20-employee threshold.
- D) Continuation or re-enrollment is never automatic; elections and requests follow the governing law or plan terms.
Memory hook
Under 20 employees, no federal COBRA — check the plan, not COBRA.