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Prepared by Mike Ewing, J.D.
Director of Research
United Actuarial Services, Inc.
(317) 580-8659
Fax (317) 580-8651
email: mewing@unitedactuarial.com
© United Actuarial Services, Inc. 2009
2009-20
March 19, 2009
DOL Posts Model COBRA Subsidy Notices and FAQs
One Notice Must Be Distributed By April 18, 2009
The Department of Labor
(DOL)
posted Model Notices; FAQs for Employers on the
COBRA Premium Reduction; Expanded FAQs for Employees on the COBRA Premium
Reduction
and Updated FAQs for Employees on General COBRA Provisions. The
Notices are available at the DOL webpage at
As reported in Client Bulletin 2009-15 and Client Bulletin 2009-19, the American
Recovery and Reinvestment Act of 2009 (ARRA) mandates that GHPs notify certain
current and former participants and beneficiaries about the premium reduction.
As required by ARRA, the DOL created model notices to help plans and individuals
comply with the
ARRA
notice requirements. Each of
the four model notices
is
designed for a particular group of qualified beneficiaries and contains information to
help satisfy ARRA’s notice provisions. The DOL’s explanation of each of the four
notices is below. The Research Department has prepared copies highlighting in red
the areas that must be filled in or optional language that GHPs should consider. It
may be possible to combine the second and fourth notices
by carefully
noting the differences and making sure all of the pertinent information is
included in the combined notice and explaining the notice applies to two
classes of individuals.
The Four Model Notices
The first notice (General Notice – Full Version) is to be used to replace the general
COBRA notice for all qualifying events occurring from
March 1, 2009 through
December 31, 2009. The second notice (General Notice – Abbreviated Version) may
be used to notify individuals who experienced an involuntary termination between
September 1, 2008 and February 16, 2009 and who elected and still have COBRA.
CLIENT BULLETIN
By April 18, 2009, group health plans (GHPs) must distribute the
“second chance” election notice to participants who experienced an
“involuntary termination” between September 1, 2008 and
February 16, 2009 but who did not elect COBRA or dropped COBRA.