Q&A: Does my company need to offer dental coverage through COBRA?

Health Plan Shopping Q&A

Each week, we feature a question from our users about Benefits Administration. Have a question of your own? email us at [email protected]

Should we offer Dental to our Employees through COBRA (the Consolidated Omnibus Budget Reconciliation Act)?

Federal Regulations:

Federal health care regulations don’t require insurance providers to cover dental care for adults, so your company isn’t obligated to offer dental coverage through either your standard health plan, or the COBRA extension of that plan.

State Regulations:

Some states have additional regulations for COBRA coverage. Often referred to as “mini-COBRA,” these regulations are generally used to require smaller companies to offer a version of COBRA coverage, even when they’re not required to under federal law. Typically, state laws make no special provisions for specific types of insurance, such as dental insurance. A simple internet search should be enough to find out whether your state has special provisions.

For example, New York’s Department of Financial Services says that employers only need to provide COBRA coverage that is identical to the previously existing plan, which is not required to include dental coverage.


To summarize, federal regulations do not require you to add additional types of coverage to a COBRA insurance plan. State regulations may require you to offer COBRA to additional classes of employees but won’t typically include provisions for anything but extending the existing plan’s coverage.

How do I decide which dental plan is best?

Here’s a great article about dental insurance to help you.

Helpful Links:

  • COBRA Rules by State – Find out whether your state has a “mini-COBRA” program or other changes from Federal regulations.
  • COBRA Coverage – Find out what COBRA covers.