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Changes to COBRA Notices and New Limited Special Enrollment Period
Drinker Biddle Link to more items from this source
[Guidance Overview]
June 5, 2014

"The new transition rule applies to federally facilitated Marketplaces, although HHS is encouraging state-run Marketplaces to adopt a similar rule.... [C]ommunications should address the impact on dental and vision continuation coverage if medical continuation coverage is dropped. Similarly, if the employer subsidizes the participant's share of the COBRA premium (e.g., during a severance period), the loss of the COBRA premium subsidy does not trigger a Marketplace special enrollment right and affected participants should be made aware of this."

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