The federal level COBRA changes, signed into law Feb. 17th, continue to create questions for employers as they implement the new requirements. Finding answers is not simple.
+ The DOL's model language published in mid March includes an error employers need to correct. The law's intent was to give a person, who has a COBRA qualifying event, 60 days from the last day of coverage to elect COBRA. The language in the model continuation coverage notification says 60 days from the date of the notice.
Thus, since many employers give or mail affected employee(s) notification and enrollment forms before the persons coverage terminates using the model letter language does not give them the correct date by which they must apply.
+ Don't just copy the model language and give it to a COBRA eligible employee. Why? There are numerous places in the 12 pages of model notices and forms where changes need to be made to make it fit the employers situation. This applies not only in the two notification pages, but in the pages with Q&A guidelines, and in the two forms a person needs to complete to enroll.
+ Some insurance companies want the person, who elects to continue coverage, to make the check out to their former employer. Thus, the employer has extra administrative work vs just sending the continuation check along with their check for the active employees.
+ The model letter for Connecticut's continuation coverage program was published by the DOI and it also needs to be modified to fit each employer.