COBRA statute of limitations period for notice violations

[Guest LBAtty]

I practice in NY and am am familiar with using the State's 3 year statute of limitations period for a COBRA notice violation claim. But, I haven't been able to determine whether such a claim is subject to the notice of claim requirements to sue a municipality/School District? Does anyone know off-hand whether a COBRA notice violation is exempt from the notice of claim requirement? Thank you.