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Benefits & ERISA Law

: Pension Protection Act Blog

Dept. of Labor Issues Model COBRA Notices

By Suzanne Wynn

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Today, the Dept. of Labor issued 4 Model Notices which can be used to comply with the notification requirements contained in the American Recovery and Reinvestment Act of 2009 (ARRA) relating to COBRA provisions.

The Model Notices are:

  • The full version General Notice which must be sent to all qualified beneficiaries, not just covered employees, who experienced a qualifying event at any time between Sept. 1, 2008 through Dec. 31, 2009, regardless of the type of qualifying event.
  • An abbreviated version of the General Notice which is the same as the full verson of the General Notice but without the COBRA coverage election information. It can be sent to individuals who experienced a qualifying event on or after Sept. 1, 2008 and have already elected COBRA coverage and still have COBRA coverage.
  • An Alternative Notice which must be sent by insurance issuers that provide group health insurance coverage to persons who became eligible for continuation coverage under a State law.
  • A Notice in Connection with Extended Election Periods which must be sent by plans subject to the Federal COBRa provisions to any assistance eligible individual (or any individual who would be an assistance eligible individual if a COBRA continuation election were in effect) who:
      • 1. Had a qualifying event at any time between Sept. 1, 2008 through Feb. 16, 2009; and
      2. Either did not elect COBRA continuation coverage, or who elected it but subsequently discontinued COBRA.

    The DOL notes that this notice must be provided by April 18, 2009.

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    Full post as published by Pension Protection Act Blog on March 19, 2009 (boomark / email).

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