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Losing your coverage: COBRA, the marketplace, and the clocks

You have more time than you think and fewer options than you are told. Here are the actual deadlines, and the two mistakes that cost people either money or coverage.

The clocks, precisely

Four deadlines run at once, and none of them starts where people assume.

60 days to elect COBRA. The window runs from the later of the day you would lose coverage or the day the election notice reaches you, not from your last day at work (26 CFR 54.4980B-6). Your election counts on the day you send it, not the day it arrives.

45 days to make the first payment, counted from the date you elect, not from anything earlier (26 CFR 54.4980B-8). That first payment has to cover everything back to the day coverage lapsed.

30 days of grace on every payment after that.

60 days for the marketplace, and this one runs in both directions: 60 days before the loss of coverage and 60 days after (45 CFR 155.420). You can line a plan up before you are uninsured rather than after.

Add the first two together and the gap between leaving a job and having to pay a single dollar commonly runs past a hundred days.

The retroactive trick nobody mentions

COBRA elected during the window is retroactive to the day coverage would have lapsed. The regulation is explicit: if the election is made during the election period, coverage must be provided from the date coverage would otherwise have been lost.

So you do not have to decide in week one. You can wait, stay technically uncovered, and if something happens, elect COBRA and pay in, and the treatment is covered. If nothing happens, you never elect and you never pay.

This is a real option, not a loophole, and it is worth thousands to someone between jobs. The risk you are carrying is that you must be able to produce the full back premium if you need to use it. Know that number before you rely on the strategy.

Why COBRA costs what it costs

Nothing about your coverage changes. What changes is that your employer stops paying its share. A plan may charge up to 102% of the full premium, the extra 2% being an administrative fee.

To see the size of that jump, the 2025 KFF employer survey puts the average family premium at $26,993 a year, of which the worker contributes $6,850. The employer was covering roughly $20,000 of it. On COBRA that becomes yours: about $2,294 a month at 102%.

If you qualify for the disability extension, months 19 through 29 may be charged at up to 150%.

Work out what COBRA would cost you

How long it lasts

  • 18 months after a job loss or a cut in hours, whether you quit or were let go
  • 29 months if Social Security determines you were disabled within the first 60 days, and you tell the plan within 60 days of that determination
  • 36 months for a spouse or dependent after a death, divorce, legal separation, or a child ageing off the plan

Measured from the qualifying event, not from the election.

The two mistakes

Assuming quitting disqualifies you. It does not. The regulation says that apart from gross misconduct, the facts surrounding the termination are irrelevant. Resigning and being fired are treated identically (26 CFR 54.4980B-4).

Dropping COBRA mid-stream expecting to switch. This is the expensive one. Voluntarily ending COBRA, or letting it lapse for non-payment, does not open a marketplace special enrollment period. Exhausting the full COBRA period does. So does the employer completely ending its contribution. Quitting on your own does not, and you wait for open enrollment (HealthCare.gov).

The practical consequence: compare COBRA against a marketplace plan before you elect, not three months in.

The marketplace side of the comparison, for 2027

One thing has changed and it changes the arithmetic for higher earners. The enhanced subsidies from 2021 expired at the end of 2025 and were not extended. The old structure is back, which means the 400% of poverty subsidy cliff applies again: one dollar of income over the line and the subsidy goes to zero, not down a little.

The IRS has now published applicable percentage tables in the pre-expansion format for both 2026 and 2027, topping out at 400% (Rev. Proc. 2026-26, released 21 July 2026). 2027 eligibility uses the 2026 federal poverty guidelines: $15,960 for a household of one, plus $5,680 for each additional person (91 FR 1797). That puts the cliff at roughly $63,840 for one person and $132,000 for a family of four.

Check where the cliff sits for your household

Do not count on the 2027 enrollment dates yet

A 2025 CMS rule would have shortened federal marketplace open enrollment to 1 November through 15 December starting with plan year 2027. That provision was vacated by a federal court in June 2026, and CMS has not published replacement dates. Some consumer sites are still carrying the 15 December date. Until CMS says otherwise, treat the 2027 window as unconfirmed and check healthcare.gov directly rather than trusting a secondary source.

Things that are easy to miss

COBRA only applies to employers with 20 or more employees. Smaller employers are covered by state continuation laws, which vary considerably.

If a spouse has employer coverage, losing yours triggers a HIPAA special enrollment right in their plan, and that window is only 30 days, far shorter than the marketplace's 60. It is frequently the cheapest option and the first one to expire.

Losing Medicaid or CHIP carries a longer 90-day marketplace window, not 60.