New Model COBRA Notices Issued by DOL
On January 13, 2010, the U.S. Department of Labor (“DOL”) issued new model COBRA notices that incorporate the changes from the Department of Defense Appropriations Act, 2010, which was signed into law by President Obama on December 19, 2009. The Act effectively extended COBRA benefits from nine to 15 months. The new notices can be found at http://www.dol.gov/ebsa/COBRAmodelnotice.html.
The new “Premium Assistance Extension Notice” should be sent to the following individuals: (1) Those who were “Assistance Eligible Individuals” and receiving the COBRA subsidy as of October 31, 2009; (2) those who were involuntarily terminated after October 31, 2009 and lost health benefits coverage, but have not been provided with the updated General Notice; and (3) those in a “transition period,” i.e., those whose COBRA subsidy ended because they had exhausted the original number of months (generally nine months), but are entitled to continue the subsidy to 15 months.
Employers should visit the the DOL and incorporate the new notice to the extent necessary and required by the law.
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