"The transition relief is targeted at certain individuals who elected COBRA outside of the regular 60-day deadline and whose initial premium deadline has already passed ... based on the premise that prior to the issuance of this guidance, they may have thought the 1-year tolling period began on their election date.... The Notice highlights that individuals who delay electing COBRA coverage may not have more than 1 year of total disregarded time for the COBRA election and initial COBRA premium payment."  MORE >>