Combined COBRA General and Election Notices

[DTH]

Has anyone ever heard of a plan administrator using a combined COBRA General and Election Notice?

I assume this is okay as long as the notices contain both sets of notification content requirements and is provided within the applicable time frame for each notice.

Thanks!

[oriecat]

That doesn't make any sense to me. The election notice has to say when coverage is ending and why. How would that be incorporated into the general notice? Just leave it blank? Say N/A? I think it would make it very confusing.

[DTH]

I thought it was odd too, but I think it could work if used as the "Important Information" section of the Election Notice. The plan administrator would attach a cover page with the reason why plan coverage ended, who is eligible for COBRA, when COBRA begins, etc. and attach a COBRA election form.

Of course the one notice would need to include information required for both notices.

[Guest Barbara Labinski]

The final regulations require employers to provide an intial notice to employees within 90 days of the date they become covered under the plan. An exception to this rule applies when the employee or qualified beneficiary becomes eligible for COBRA during that intial 90 day period. The plan may choose to provide only the COBRA election notice and omit the initial notice.