New Developments and Impending Deadlines for Employer Group Health Plans

Patterson Belknap Webb & Tyler LLP
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As the federal government agencies continue to push forward with implementation and administration of health care reform (i.e., the Patient Protection and Affordable Care Act), there are two recent developments that we want to highlight that should be of interest to employers who sponsor group health plans. We also discuss an impending deadline for employers who sponsor self-insured health plans.

DOL Issues New COBRA Continuation Coverage Notices -

Earlier this year, the U.S. Department of Labor (“DOL”) indicated that its ten-year old model COBRA notices, issued in 2004 with the original regulations under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), were outdated. To that end, the DOL issued updated versions of: the model COBRA general notice1 and the model COBRA election notice.2 The updated notices generally reflect the existence and implication of the Health Insurance Marketplace as a result of the Patient Protection and Affordable Care Act. As a reminder, COBRA, and its applicable notice requirements, generally apply to a group health plan for a calendar year if the employer maintaining the plan employs 20 or more employees on a typical business day during the preceding calendar year.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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