The U.S. Department of Labor has issued four model COBRA notices which cover the provisions of the American Recovery and Reinvestment Act of 2009. These model notices will enable employers to notify former employees and their dependents how to take advantage of COBRA coverage and the subsidy.
There are four new notices available for different types of plans and individuals:
- General Notice (Full version) – Send this notice to ALL qualified beneficiaries going forward. This combines a general COBRA notice with the premium reduction provisions of ARRA.
- Abbreviated Version of the General Notice – This notice covers just the premium reduction information under ARRA – Send this notice to individuals who experienced a qualifying event during on or after September 1, 2008, have already elected COBRA coverage, and still have it.
- Alternative Notice – This notice is sent to persons who became eligible for continuation coverage under a State law. Plans will need to modify notice to bring it into compliance with their applicable state law.
- Notice in Connection with Extended Election Periods – This notice includes information on ARRA’s special election opportunity along with the premium reduction information. This notice MUST be provided to these individuals by April 18, 2009. Plans subject to the Federal COBRA provisions MUST send this notice any “assistance eligible individual” who:
a. Had a qualifying event at any time from September 1, 2008 through February 16, 2009; and,
b. Either did not elect COBRA continuation coverage, or who elected it but subsequently discontinued COBRA.
Additional References
http://www.dol.gov/ebsa/COBRAmodelnotice.html
http://www.dol.gov/ebsa/faqs/faq-cobra-premiumreductionEE.html
