<H3>• “New Model COBRA Notices Should be Used by U.S. Employers”</H3>

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”The U.S. Department of Labor has published a new model general COBRA notice and a new model election COBRA notice. The new model notices reflect that coverage is available in the public health insurance exchanges, i.e., the 'Marketplace,' and include information on special enrollment rights in the Marketplace. "Use of these model notices, properly completed, will be considered good faith compliance with the notice content requirements of COBRA…. See the complete report at this link: JacksonLewis.com The Departments of Labor, Health and Human Services, and Treasury are also publishing frequently asked questions related to the proposed changes to model notices. The FAQs are posted on the Department of Labor website at http://www.dol.gov/ebsa/faqs/faq-aca19.html and the HHS website at http://www.cms.gov/CCIIO/Resources/Fact-Sheets-and-FAQs/aca_implementation_faqs19.html. In addition, HHS is publishing a clarifying bulletin regarding a special enrollment period in the Marketplace for individuals already enrolled in COBRA continuation coverage. The bulletin is posted on the HHS website at http://www.cms.gov/CCIIO/Resources/Regulations-and-Guidance/Downloads/SEP-and-hardship-FAQ-5-1-2014.pdf. The updated model notices are posted on the Department of Labor website at http://www.dol.gov/ebsa/modelgeneralnotice.doc and http://www.dol.gov/ebsa/modelelectionnotice.doc. A related notice of proposed rulemaking on the COBRA notice requirements will be published in the May 7 edition of the Federal Register. The notice of proposed rulemaking can also be viewed here.

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