Group health plans for employers with 20 or more employees on more than 50 percent of its
typical business days in the previous calendar year are subject to COBRA. Both full and part-time
employees are counted to determine whether a plan is subject to COBRA. Each part-time employee
counts as a fraction of an employee, with the fraction equal to the number of hours that the part-time
employee worked divided by the hours an employee must work to be considered full-time.