Claimants do not have to meet the non-disability requirements for Title II (e.g.,
insured status or an onset date more than 5 months before full retirement age (FRA))
or Title XVI (e.g., income or resources) to qualify for the additional 11 months of
health care benefits under COBRA. To ensure that the claimant receives a prompt determination, handle all COBRA claims
If the disability determination services (DDS) or the Philadelphia disability processing
unit (PH-DPU) finds the employee, spouse, or dependent child disabled under the Social
Security Act within 60 days of the COBRA qualifying event, he or she may receive an
additional 11 months of health care benefits under COBRA. The Social Security Administration
(SSA) is only responsible for making disability decisions for the extension of COBRA
coverage (the additional 11 months). See DI 11080.001 for additional details about the qualifying events and SSA’s responsibility.
For Title II and concurrent cases, the DDS determines an onset as in any Title II
disability claim. We use the onset date, established by the DDS, to determine eligibility
In Title XVI-only cases, the DDS usually uses the date of filing or protective date
of filing as the onset. In COBRA cases, however, the DDS must establish an actual
medical onset date. If this is not possible, the DDS attempts to establish disability
within the first 60 days of COBRA coverage.
To extend health care coverage under COBRA based on disability, the individual must:
File for disability benefits (Title II, Title XVI, or concurrent) with COBRA extension,
File for COBRA extension only.
Claims in which the individual files for disability benefits and requests a COBRA
determination are the jurisdiction of the DDS. COBRA only determinations are the jurisdiction
of the PH-DPU. See DI 11080.005E in this section.
IMPORTANT: While the SSA does not require proof of COBRA entitlement (such as dates of entitlement
to COBRA, relationship, date decision required), it is in the claimant’s best interest
to provide verification in order to make a timely decision.