Many plans may not realize how many different required COBRA notices federal law includes. COBRA actually requires several different notices depending on a host of facts or conditions. Some of these notices also include model language published by the regulators.
Some details of these required COBRA notices:
a. Initial Notice: Communicate general COBRA rights and obligations. DOL Model Notice:
http://www.dol.gov/ebsa/modelgeneralnotice.doc
b. Election Notice: Notice of rights and obligations regarding a specific qualifying event. DOL Model Notice (revised to include exchange information on 5/8/13):
http://www.dol.gov/ebsa/modelelectionnotice.doc
c. Notice of Unavailability of Coverage: Explanation of why COBRA coverage or extension is not available.
d. Notice of Early Termination: If COBRA coverage terminates before end of maximum coverage period, must provide notice of termination.
e. Short Premium Payment Notice: If COBRA payment is short by an insignificant amount, provide notice of amount of deficiency and period for correcting.
f. Summary Plan Description: Description of COBRA coverage and rights should be included within SPD.
If you need assistance understanding how to comply with these rules or other COBRA questions, please contact Kinney & Larson.