"Under the previous version of HCTC, individuals who had dropped or not elected continued health coverage under [COBRA] would, under limited circumstances, have a 60-day special enrollment right triggered by becoming eligible for [Trade Adjustment Assistance (TAA)]. The [DOL] has not yet issued guidance as to the application of COBRA to the new extension of HCTC. Moreover, the DOL has not yet provided guidance on whether COBRA notices should include information about the HCTC extension."