PPACA FAQs Part 32 – COBRA Notice May Include Additional Information about Exchange Options

PPACA FAQs Part 32 – COBRA Notice May Include Additional Information about Exchange Options

DOL_imageThe Departments (DOL, HHS, and IRS) have jointly issued a single FAQ confirming that group health plan administrators may include in their COBRA election notices information about Exchange coverage that goes beyond the information included in the DOL’s model notice.

As you may recall, the DOL revised its model election notice in 2013 and again in 2014 to include basic information about the Exchanges (federal and state Marketplaces).  See links below, or this Model Notices from the DOL’s site (in English).

FAQ Part 32 states that administrators may include additional information, such as:

  1. how to obtain assistance with Exchange enrollment (including special enrollment);
  2. the availability of financial assistance;
  3. information about Exchange websites and contact information;
  4. general information regarding particular products offered in the Exchanges; and
  5. other information that may help qualified beneficiaries choose between COBRA and other coverage options.

The Departments do encourage employer, plan sponsors and plan administrators to consider how they can help individuals maintain the coverage that would best suit their needs and they note that COBRA notices may be tailored to particular groups, such as young adults aging out of dependent coverage under their parents’ health plan.

FAQ-32 also includes a reminder that COBRA notices must be “easily understood by the average plan participant.”

While use of the DOL’s model COBRA notice is not required (not mandatory at all), many plans choose to use the model as the basis for their notices because it covers all the points that are required to be covered per federal guidance.  Naturally, you are expected to customize that to include helpful and relevant contact information, plan specific details, process for selecting and paying for coverage, etc.

Should you have any questions or concerns, please contact your Account Manager or Account Executive.

Links

COBRA Continuation Coverage – Resources for Employers: