HELP! -WC and COBRA

We have an employee who went on worker's compensation over two years ago. He was still an employee while on wc leave, entitled to participation in our group health coverage. However, he did not pay his portion of the premiums timely and the coverage was terminated for non-payment well over 1 1/2 year ago. He only recently was terminated from employment. Is this termination from employment a "qualifying event" requiring me to send a COBRA notice to him? I am not certain since he was not covered at the time of termination.
If anyone knows of the regulation which might address this, i would really appreciate it or any thoughts on this issue? Thanks!

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