Jill has a group health plan with an employer that covers employees in more than one state. Which of the following is NOT affected by the state regulatory jurisdiction established for this plan?

• A. Eligibility requirements
• B. Required provisions
• C. Minimum enrollment percentage
• D. Continuation of coverage under COBRA

Answer: (D)

When a group health plan covers employees in more than one state, state regulators oversee many operating details of the plan, including who must be covered (eligibility), the terms that must appear in the policy (required provisions), and participation levels or enrollment requirements (minimum enrollment percentage). These areas are shaped by state insurance laws and regulations.

But continuation of coverage under COBRA is dictated by federal law. The COBRA statute requires employers to offer extended coverage after certain qualifying events, with the rules set and enforced at the federal level. States can’t override or materially change those rights, though they can offer their own additions (state mini-COBRA) that extend beyond the federal requirements. That federal basis is why continuation of COBRA coverage is not affected by state regulatory jurisdiction.