Short answer: Only if it does so for other employees in a similar leave status. The ADA requires equal treatment, not FMLA-style health continuation.
The EEOC’s reasonable accommodation guidance says an employer must continue an employee’s health insurance during ADA leave only if it does so for other employees in a similar leave status. The employee must be allowed to use accrued paid leave first, then unpaid leave.
This is where FMLA and ADA differ. FMLA leave (up to 12 weeks for eligible employees) requires the employer to keep group health coverage on the same terms. Once FMLA ends, or for an employee who never qualified, coverage follows the employer’s written leave policy and the plan’s eligibility rules, applied the same way to everyone.
Practical steps: check that the carrier contract or plan document allows coverage to continue during a leave of absence and for how long, put the employer’s rule in writing, and apply it consistently. If coverage ends, the loss is generally a COBRA (20 or more employees) or Texas state continuation event.