18 to 36-Month Period (Second Qualifying Event): A spouse and dependent children who already have COBRA coverage, and then experience a second qualifying event, may be entitled to a total of 36 months of COBRA coverage. Second qualifying events may include...the covered employee becoming entitled to Medicare benefits (under Part A, Part B or both). The following conditions must be met in order for a second event to extend a period of coverage:
1. The initial qualifying event is the covered employee's termination or reduction of hours, of employment, which calls for an 18-month period of continuation coverage;
2. The second event that gives rise to a 36-month maximum coverage period occurs during the initial 18-month period of continuation coverage;
3. The second event would have caused a qualified beneficiary to lose coverage under the plan in the absence of the initial qualifying event;
4. The individual was a qualified beneficiary in connection with the first qualifying event and is still a qualified beneficiary at the time of the second event; and
5. The individual meets any applicable COBRA notice requirement in connection with a second event...
If all conditions associated with a second qualifying event are met, the period of continuation coverage for the affected qualified beneficiary (or beneficiaries) is extended from 18 months to 36 months.
Reference:
https://www.cms.gov/CCIIO/Programs-...tections/cobra_fact_sheet#Periods_of_Coverage
