COBRA MODEL NOTICES ISSUED BY DOL
On March 19, the Department of Labor issued their model notices for COBRA as part of the American Recovery and Reinvestment Act of 2009 which was passed last month by Congress. The forms applicable for COBRA Continuation Coverage Assistance under the Act are available on the DOL website. The 4 separate notices are designated as general notice (full version), general notice (abbreviated version), alternative notice and notice in connection with extended election periods. All COBRA eligible employees, and their qualified beneficiaries, involuntarily terminated between September 1, 2008, and December 31, 2009, qualify for the 65% subsidy on COBRA premiums. Former employees who elect to use the subsidy are responsible for 35% of the premium, and the employer is responsible for the other 65%, which will be recovered as a credit against their quarterly payroll taxes.
Practice Pointer. Employers are required to give notice to employees of the available subsidy (and have been required since February 17, 2009) and the employee and qualified beneficiaries have 60 days to decide whether to sign up for the subsidized COBRA program.
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