What Employers Must Offer Insurance Under COBRA?
COBRA technically applies to health plans and a health plan is subject to the COBRA rules if the employer employs twenty or more employees on more than fifty percent of its business days, counting both full-time and part-time employees. Part-time employees count as fractions of an employee based on their hours as a percent of a full work week, forty hours. If the health plan is subject to COBRA rules, your employer is required by law to notify you of their responsibility to provide COBRA in the event of a qualify event.
Now, If your employer no longer offers health coverage of any kind (say, because of bankruptcy) then they are not required to offer health coverage under COBRA (since it applies to the health plan, not the employer).
For example, if John is one of thirty employees working for Company A and he loses his job (a qualifying event) because Company A goes out business, then he is not eligible for health coverage under COBRA because that health coverage no longer exists. The fact that the employer must offer insurance under COBRA to John because he lost coverage because of a qualifying event is irrelevant because Company A no longer exists.