Yes, an employer that is subject to COBRA must offer dental coverage under the same circumstances as any other health plan.

Group health coverage. COBRA requires employers subject to the law to allow COBRA-qualified beneficiaries to continue the employer-provided group health coverage in which the beneficiary was enrolled on the day before the beneficiary experienced a COBRA-qualifying event that would cause the beneficiary to lose the group health coverage. A group health plan is defined as “any plan, including dental and vision, maintained by an employer or employee organization to provide health care to individuals who have an employment-related connection to the employer or employee organization or to their families.”

Covered on day before event? If, on the day before a COBRA-qualifying event (for example, termination of employment), a beneficiary is covered under the employer's separate health, dental, and vision plans, for example, then the beneficiary must be given the opportunity to continue coverage under all three plans. Thus, if active employees may elect coverage under these plans separately, then the COBRA beneficiary also may elect COBRA continuation separately for each of these options.

However, if employees only can take these “plans” as a single package, then the COBRA beneficiary can continue only the entire package. And, at open enrollment or HIPAA special enrollment, the COBRA beneficiary may change coverage elections, just as active employees may do.

Source: Spencer’s Benefits Reports.