To be exempt from COBRA, a plan must be a "church plan," as defined in 29 U.S.C. 1002(33). You may want to carefully review the true facts about your employer's plan and see if it actually satisfies the requisite definition (see previous link). For example, if the plan is intended to cover employees who are involved in a trade or business unrelated to church functions.

Regardless, of the existence or nonexistence of church exemption, where an employer has no health care coverage at all, its employees have no continuation coverage -- because there is nothing to continue. So, in some respects, the issue is moot, except for the purposes of obtaining a HIPAA individual conversion plan -- which is generally too expensive for anyone.

What people in your position usually do is try to obtain individual coverage, and if denied, then they opt for the State MRMIP (Major Risk Medical Insurance Program) -- or the federal PCIP (Preexisting Condition Insurance Program). For info, see this link.

Hope this helps.

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