COBRA and Open Enrollment: A Houston Employer Guide
Separate employer enrollment, Marketplace dates and COBRA deadlines, including the Texas continuation rules that may apply.
2 min readBy Dustin Neider
Key Takeaways
- Employer annual enrollment is set by the plan, not HealthCare.gov.
- COBRA elections follow event-based notice and election periods.
- For 2026 HealthCare.gov coverage, open enrollment ran November 1, 2025–January 15, 2026.
- Texas continuation can apply to eligible insured plans, not self-funded ERISA plans.
Houston employers should manage three separate calendars: the group plan’s annual enrollment, Marketplace open enrollment and event-based COBRA deadlines. Texas continuation may add another coverage option for eligible insured plans. None of these calendars automatically replaces the others, so employees need the correct notice, effective date and payment instructions before changing or ending existing coverage.
Which enrollment calendar applies?
| Coverage route | Timing | Employer action |
|---|---|---|
| Employer annual enrollment | Dates established by the group plan. | Confirm the plan-year changes and communicate options to active employees and eligible COBRA participants. |
| HealthCare.gov, 2026 example | November 1, 2025–January 15, 2026; December 15 for January 1 coverage. CMS dated fact sheet | Do not describe December 15 as the end of the entire Marketplace enrollment period. |
| COBRA initial election | At least 60 days from the later of coverage loss or provision of the election notice. DOL employer guide | Track the event and notices separately from annual enrollment. |
What COBRA notice periods should HR track?
Under the DOL employer guide, employers generally notify the plan administrator within 30 days of events such as termination or reduction of hours; the administrator generally provides the election notice within 14 days after notification. When the employer is also administrator, the combined rule generally allows 44 days, measured under the applicable event/coverage-loss rules. Do not use 44 days as a universal rule for every event or plan arrangement.
The initial premium is generally due within 45 days after election. Qualified beneficiaries have their own notice duties for certain events, including divorce or loss of dependent status, under the plan’s procedures. Assign responsibility with the administrator and keep evidence of delivery. Annual enrollment does not restart these initial election or payment periods.
How does Texas continuation differ?
TDI explains Texas continuation: eligible people may receive up to nine months when not eligible for COBRA, or six additional months after exhausting COBRA. State continuation applies to eligible insurance-company and HMO plans subject to Texas insurance law, not self-funded ERISA plans. Confirm eligibility, prior coverage, notice and payment requirements with the carrier rather than assume every departing employee qualifies.
What should employees compare before cancelling coverage?
Compare premium, network, prescriptions, deductible credit and effective dates. Marketplace special enrollment rules distinguish exhaustion of COBRA from voluntarily ending it early; voluntary cancellation generally does not itself open a special enrollment period. Have employees confirm their actual enrollment route before dropping coverage. Send current annual enrollment materials to eligible COBRA participants rather than treating them as excluded former employees.
See also qualifying events and special enrollment and our employer compliance support.
General information for employers, not legal, tax, or medical advice; plan documents and current rules control.
To review your employer-plan questions, contact PCI Solutions.
Frequently Asked Questions
Does employer open enrollment restart the COBRA election period?
No. The initial COBRA election deadline is based on loss of coverage and the election notice, not the annual enrollment calendar.
Can someone drop COBRA and immediately enroll in the Marketplace?
Voluntarily ending COBRA early generally does not by itself create a Marketplace special enrollment period. Open enrollment or another qualifying event may allow enrollment; verify before cancelling.
Does Texas continuation cover self-funded plans?
Texas state continuation does not apply to employer self-funded ERISA plans. Confirm whether the plan is insured and whether the person meets the state eligibility and notice rules.
About the author
Dustin Neider — President of PCI Solutions, insurance broker and ACA specialist with nearly 20 years of experience in health insurance.
