New Temporary Extension Model COBRA Notices Released
|
The Temporary Extension Act of 2010 (TEA) mandates that plans notify certain current and former participants and beneficiaries about the premium reduction extension. The Department of Labor has updated its existing model notices and created several additional notices to help employers and plan administrators comply with these requirements. Each model notice is designed for a particular group of individuals and contains information to help satisfy ARRA's notice provisions, including those added by TEA.
Updated Model General Notice: This notice must be provided to all qualified beneficiaries, not just covered employees, who experienced a qualifying event at any time from September 1, 2008 through March 31, 2010, regardless of the type of qualifying event, and who have not yet been provided an election notice. Plans must provide the updated General Notice within the required timeframes for providing a COBRA election notice. The updated model General Notice includes information on the premium reduction as well as information required in a COBRA election notice.
Model Notice of New Election Period: This notice should be provided to all individuals who:
-
reductions of hours that occurred during the period from September 1, 2008 through March 31, 2010 which were followed by a termination of the employee's employment that occurred on or after March 2, 2010 and by March 31, 2010.
Model Notice of Extended Election Period: Must be provided to all individuals who experienced a qualifying event that was a termination of employment some time on or after March 1, 2010, and were provided a notice that did not inform them of their rights under ARRA, as amended by TEA, and either chose not to elect COBRA continuation coverage at that time or elected COBRA but subsequently discontinued that coverage. This notice must be provided before the end of the required time period for providing a COBRA election notice.
Model Updated Alternative Notice: Insurance issuers that provide group health insurance coverage must provide notice to persons who became eligible for continuation coverage under a State law. This updated model notice will assist issuers with satisfying this requirement. However, continuation coverage requirements vary among States and issuers will need to modify this model notice as necessary to conform it to the applicable State law.
This latest extension merely provides immediate relief, since the premium assistance under the Department of Defense Appropriations Act, 2010 expired February 28, 2010. Please note that Congress is considering a further extension and expansion of the ARRA COBRA subsidy. We will continue to monitor and report on developments as they occur.
Sullivan Benefits clients receive COBRA administration services at no additional cost. Whether you currently utilize this service or not, the Sullivan Benefits Team is here to assist you in understanding and implementing these new provisions.
As always, please contact us with any questions or assistance in complying with the new COBRA regulations. |
|
Needham Heights Office:
72 River Park · Needham Heights, MA 02494-2631
Phone: 781.449.8323 · Fax: 781.449.5419
Worcester Office:
One Chestnut Place · Worcester, MA 01608-2804
Phone: 508.471.9017 · Fax: 508.797.3689
|
