Key Takeaways

  • California requires group life insurance policies to include a conversion privilege allowing departing employees to convert to individual coverage within 31 days
  • Small group health insurance in California applies to employers with 1-100 employees (expanded from federal 1-50 definition)
  • Cal-COBRA provides continuation coverage for employers with 2-19 employees not covered by federal COBRA
  • California law requires group health plans to cover mental health and substance abuse at parity with medical benefits
  • Employers must provide certificates of coverage explaining benefits, eligibility, and continuation rights
Last updated: January 2026

California Group Life and Health Insurance Requirements

California has extensive regulations governing group life and health insurance, with some of the strongest employee protections in the nation.

Group Life Insurance Requirements

Conversion Privilege

California requires group life policies to include a conversion privilege:

RequirementDetails
Who QualifiesEmployees and dependents losing group coverage
Conversion Period31 days from termination
No Evidence RequiredCannot require proof of insurability
PremiumStandard individual rates for age
Coverage AmountUp to amount of group coverage

When Conversion Rights Apply

Employees have conversion rights when:

  • Employment is terminated (voluntary or involuntary)
  • Employee retires
  • Employee's class is eliminated
  • Group policy is terminated (with proper notice)
  • Dependent loses coverage status

Exam Tip: The 31-day conversion period is a key California requirement. During this period, the employee remains covered under the group policy even if they haven't yet applied to convert.

Death During Conversion Period

If an employee dies during the 31-day conversion period:

  • Group coverage still applies
  • Death benefit is paid as if coverage continued
  • Conversion application status is irrelevant

Small Group Market Definition

California's Expanded Definition

California defines small groups more broadly than federal law:

MarketGroup Size
California Small Group1-100 employees
Federal Small Group1-50 employees
California Large Group101+ employees

Small Group Protections

California small group plans must provide:

  • Guaranteed issue (cannot deny coverage)
  • No pre-existing condition exclusions
  • Essential health benefits
  • Mental health parity
  • Guaranteed renewal

California Mental Health Parity

California requires mental health parity in group health plans:

Parity Requirements

RequirementDetails
Coverage LevelSame as medical/surgical benefits
Cost SharingSame copays, deductibles, coinsurance
Visit LimitsCannot be more restrictive than medical
Treatment LimitsSame as comparable medical treatment

Covered Conditions

California parity covers:

  • Schizophrenia
  • Bipolar disorder
  • Major depressive disorder
  • Obsessive-compulsive disorder
  • Panic disorder
  • Autism spectrum disorders
  • Substance use disorders
  • Other severe mental illnesses

Network Requirements

Insurers must provide:

  • Adequate network of mental health providers
  • Same access standards as medical providers
  • Timely access to treatment

Certificate of Coverage Requirements

California requires detailed certificates:

Required Contents

ElementDescription
Benefits SummaryWhat the plan covers
Eligibility RulesWho is covered and when
Effective DatesWhen coverage begins and ends
Premium InformationCost and payment details
Conversion RightsHow to convert to individual coverage
Continuation RightsCOBRA and Cal-COBRA options
Claims ProceduresHow to file claims
Appeal RightsHow to appeal denied claims
Contact InformationInsurer and administrator info

Timing of Certificate Delivery

  • Within 15 days of coverage effective date
  • Updated certificate for material changes
  • Summary of Benefits and Coverage (SBC) also required

Dependent Coverage Requirements

Age 26 Coverage

California follows federal requirements for dependent coverage:

RequirementDetails
Age LimitCoverage to age 26
Marital StatusDoesn't matter
Student StatusDoesn't matter
Financial DependenceDoesn't matter
Own Employer CoverageCan still be on parent's plan

Domestic Partner Coverage

California requires domestic partner coverage:

  • Same coverage as married spouses
  • Same premium contribution rules
  • Same COBRA/Cal-COBRA rights
  • Tax treatment differs from spouse coverage

Coordination of Benefits

When employees have multiple group plans:

California Coordination Rules

SituationPrimary Plan
Employee's own planPrimary for employee
Employee as dependentPrimary plan pays first
Children (birthday rule)Parent with earlier birthday month/day
Children of separated/divorcedCourt order or specific rules

Birthday Rule Details

The birthday rule determines which parent's plan is primary for children:

  • Uses parent's birthday month and day (not year)
  • Earlier birthday in calendar year = primary plan
  • If same birthday, parent covered longer is primary

Employer Contribution Requirements

Minimum Participation

Contribution TypeMinimum Participation
Employer-paid (100%)100% of eligible employees
ContributoryTypically 75% participation

Small Employer Rules

Small employers may have different participation requirements:

  • May have lower minimum participation
  • Guaranteed issue regardless of participation
  • Cannot be charged more for low participation

Exam Tip: California's small group market includes employers with 1-100 employees, which is broader than the federal 1-50 definition. This expands guaranteed issue protections.

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California Group Life Insurance Conversion
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How many employees are in California's small group market?

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How long do employees have to convert group life insurance to individual coverage in California?

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Does California require domestic partner coverage in group health plans?

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Under the birthday rule, which parent's plan is primary for a child?

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What is required for mental health coverage in California group health plans?

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