The DOL has released the Model COBRA Notices for use with all new election notifications, as well as notifications for individuals that experienced involuntary terminations and are still in their initial 18 month COBRA period, under the ARPA subsidy rules. The full list of Model notices can be viewed here, under the ‘model notice’ sub header. The first page of each notice contains a brief description of which individuals it applies to.
- The Model General Notice of COBRA Continuation (for all NEW terminations occurring between April 1 and Sept 30, as well as all current COBRA enrollees that are up to date on all premiums),
- The Extended Election Notice (for all individuals that were involuntarily terminated/had reductions in hours back to November 2019, but either let COBRA lapse or never enrolled, and have a new election period under the ARPA), and
- The Model Notice of Expiration of Premium subsidy (required to be sent at least 15 days before the subsidy will end for any enrolled participant)
Employer Action: Employers should either prepare to edit and send the appropriate notices to all impacted individuals, or confirm any COBRA vendor is handling this notification (there will usually be a fee for this additional service). The notification must be sent by May 31, 2021.