“If the initial qualifying event that triggers an individual’s COBRA rights is terminating employment or reducing hours of employment, subsequent qualifying events may result in an extension of the maximum COBRA coverage period for certain qualified beneficiaries…. Note that a covered employee is not a qualified beneficiary with respect to any 36-month qualifying event. Therefore, the expanded period that applies in connection with a second qualifying event will not apply to a covered employee but only to the spouse or a dependent child of a covered employee.” But, does the extended COBRA coverage to which the dependent would be entitled run from the date of the second qualifying event or from the employee’s termination date? [Willis Towers Watson]