It's something else, and you can decline COBRA and sign up for ACA because of the (voluntary) loss of employment. You get a special enrollment period.
You're probably right. It would be the common sense way for things to be. The state does not contribute anything toward the cost of COBRA insurance, which would close to quintuple our health insurance costs; it's hard to see how that could be regarded as the same as being offered the employee health benefit plan.
Still, to verify I called the US DOL using the number provided. They only deal with private COBRA, but they still helped me by providing the following contacts ...
1-877-267-2323, option 6, extension 61565 for COBRA questions (I got a voicemail, didn't leave a message)
and
phig@cms.hhs.gov
Based on the voice message at the phone number, these are absolutely the right people to whom to ask these kinds of questions. I didn't leave a voicemail. But, I sent an email earlier today inquiring about this issue. I'll report back after I (hopefully) get a clear response.