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Model Notices

ARRA mandates that plans notify certain current and former participants and beneficiaries about the premium reduction.

The Department of Labor created model notices to help plans and individuals comply with these requirements. Each model notice is designed for a particular group of qualified beneficiaries and contains information to help satisfy ARRA’s notice provisions.

The notices are available at the DOL Web site.

Not sure which notice to send? The information below provides a brief overview of which notice should be sent and when.

All Qualifying Events Other Than Involuntary Termination

Send Nothing: Qualified beneficiaries who had a qualifying event of divorce, death of the employee, loss of dependent status, entitlement to Medicare, or voluntary termination at any time from September 1, 2008 through February 16, 2009 and who were provided a COBRA election notice before February 17, 2009 that was in compliance at the time it was sent and did NOT elect COBRA.

Note: If you are unsure if this person had a voluntary or involuntary termination, treat the person as involuntary and send the Model Notice in Connection with Extended Election Periods. IRS will be releasing guidance on the definition on "involuntary" shortly.

Send the Abbreviated Notice: Qualified beneficiaries who experienced a qualifying event on or after September 1, 2008 and are on COBRA currently. Even though these people are not eligible for the subsidy because they had a qualifying event other than involuntary termination, they must be given a notice.

Send the Full Version General Notice: Qualified beneficiaries who experienced a qualifying event at any time from September 1, 2008 through December 31, 2009 AND who were provided an election notice on or after February 17, 2009 that did not include the additional information required by ARRA, or have not been sent an election notice yet. These individuals will receive a 60-day election period from the date the additional information on the COBRA subsidy is provided.

Involuntary Termination Qualifying Event

Send Notice in Connection with Extended Election Periods: "Assistance eligible individuals" (or any individuals who would be "assistance eligible individuals" if COBRA were in effect) who had a qualifying event at any time from September 1, 2008 through February 16, 2009, AND either did not elect COBRA or who elected but subsequently discontinued COBRA. This notice must be provided by April 18, 2009.

Send the Abbreviated Notice: Qualified beneficiaries who experienced a qualifying event on or after September 1, 2008 and are on COBRA currently.

Send the Full Version General Notice: Qualified beneficiaries who experienced a qualifying event at any time from September 1, 2008 through December 31, 2009 AND who were provided an election notice on or after February 17, 2009 that did not include the additional information required by ARRA, or have not been sent an election notice. These individuals will receive a 60-day election period from the date the additional information on the COBRA subsidy is provided.

Source: Society of Professional Benefit Administrators