I would not trust any answer you got on here. I suggest going to the PBGC or IRS for the answer. One problem you have is the definition of a
qualified plan. For instance, I am past 65 and have Medicare Part A only because American's group insurance is a qualified plan therefore I do not have to sign up for Parts B, C, and or D yet.
How do I know it's a qualified plan? AA sends me a letter each year stating that the AA Medical insurance is a qualified plan under Federal standards. By qualified, they mean that AA's group insurance provides as good or better coverage than Medicare.
And, you can't translate that qualification into a qualification for the insurance you have. The PBGC probably has totally different standards for determining if a policy is qualified..
I would start with determining whether or not the pre-65 Insurance meets the standard for being a qualified plan. From what you have posted, it sounds like a pursuit well worth making. A tax credit for the premiums you pay? Go for it. If it provides the same benefits available to full-time employees, I would say yes it's qualified, but what do I know? I'm a flight attendant. I'm paid to be cute, not smart.