A Virginia employer is NOT subject to the federal COBRA continuation framework. Under Va. Code § 38.2-3541, how long a continuation of health coverage must the employer offer a qualified person after a qualifying event?

Why C is correct

Va. Code § 38.2-3541 is Virginia's mini-COBRA: an employer not subject to the federal COBRA framework must offer 12 months of continuation coverage to a qualified person after a qualifying event. The state requirement stands on its own — the employer cannot avoid continuation obligations merely because federal law does not reach it, and the Virginia Bureau of Insurance enforces the statute. Remembering 12 months as the Virginia state duration keeps it distinct from the longer periods federal COBRA provides for certain events.

Why the other options are wrong

• A) 18 months is the base duration under the federal COBRA framework for certain events; the Virginia state requirement at Va. Code § 38.2-3541 is 12 months.
• B) 6 months understates the Virginia continuation period and belongs to other rules entirely, such as preexisting-condition look-back windows.
• D) 24 months is not the Virginia continuation duration; the state requirement is 12 months under Va. Code § 38.2-3541.

Memory hook

No federal COBRA? Virginia still says 12 months.