• COBRA Continuation Coverage New Regulations Issued by Department of Labor on Notice Requirements Changes in COBRA Communication Materials/Procedures Required
  • September 11, 2003 | Authors: James T. Rauschenberger; Roger T. Weitkamp; Stacy L. Dewalt
  • Law Firm: Arnall Golden Gregory LLP - Atlanta Office
  • The Consolidated Omnibus Budget Reconciliation Act ("COBRA") requires most employer-sponsored group health plans to provide employees and their dependents the opportunity to continue their group health coverage for a limited period of time (such continued coverage is referred to as "COBRA Coverage") following the occurrence of certain events (called "Qualifying Events") that would otherwise result in a loss of coverage under a group health plan. Among other things, COBRA requires that employers issue certain communications/notices concerning COBRA Coverage to individuals covered under group health plans. Since the enactment of COBRA in 1985, there has been very little guidance issued concerning most aspects of these notice requirements. The U.S. Department of Labor (the "DOL") issued proposed regulations (the "Regulations") this summer concerning the notice and disclosure provisions of COBRA. If finalized, the Regulations will become effective on the first day of the first plan year that begins on or after January 1, 2004. This Bulletin briefly summarizes COBRA's statutory notice requirements and highlights the key provisions of the Regulations.