COBRA Termination Notification?

We have a former employee who exhausted her 18 months of COBRA. She sent a check for December even though that would be her 19th month. I called her (on 12/8) to tell her that her that I was returning her check as coverage ended 11/30/03. She claims that we were required to give her notice that her 18-month COBRA eligibility had expired, as well as notify her of options to convert her coverage to an individual policy. I have never heard of such a requirement, have any of you?

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