Although plan administrators are not required to use the updated model notices, the DOL generally considers their use—with the addition of appropriate plan information—to be good faith compliance with COBRA’s content requirements for:
- The general notice of coverage continuation rights, which must be provided to each employee and spouse within 90 days of coverage; and
- The notice of a qualified beneficiary’s right to elect continued coverage, which must be provided within 14 days after receiving notice of a qualifying event.
Updates and FAQs Address Medicare-COBRA Interactions
As explained in a set of answers to frequently asked questions (FAQs) the DOL also issued on May 1, 2020, the updated model notices aim to help qualified beneficiaries better understand the interactions between Medicare and COBRA.
Specifically, the updated models indicate that there may be advantages to enrolling in Medicare before, or instead of, electing COBRA. They also highlight that if an individual is eligible for both COBRA and Medicare, electing COBRA coverage may impact enrollment into Medicare and certain out-of-pocket costs.
Additional details about Medicare and COBRA enrollment options are also included in both the FAQs and updated model notices.
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