Employee Benefits Security Administration Issues Model COBRA Notices

March 19, 2009

Today, the Employee Benefits Security Administration (EBSA) issued the model COBRA notices which were required by the American Recovery and Reinvestment Act of 2009 (ARRA). We issued a legal update on February 25th that summarized the impact of ARRA on an employer’s COBRA obligations (both state and federal). For your reference, follow this link to the legal update.
The model notices include a “General Notice (Full Version)” which is intended to be used for all qualifying event notices for ALL qualifying events from and after September 1, 2008 and through December 31, 2009. The “General Notice (Abbreviated Version)” is intended to be used for assistance eligible individuals who were still on COBRA on February 17, 2009, and therefore need to be alerted to the COBRA premium reduction. The “Alternative Notice” applies to group health plans which are not subject to federal COBRA, but are subject to a state continuation coverage law. Finally, the “Notice in Connection with Extended Election Periods” is intended to be sent to those who would have been assistance eligible individuals had they continued COBRA coverage through February 16, 2009, and who must be notified of their right to elect COBRA continuation coverage effective March 1, 2009.
If you have questions concerning this legal update or the COBRA provisions in ARRA, please contact Mary Ellen Schill, the author of this article, or any of the attorneys in the Employment, Benefits & Labor Relations Practice Group of Ruder Ware.

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