Kelley Drye's Employee Benefits and Executive Compensation
Practice Group has prepared a client advisory discussing the final regulations recently issued by the Department of Labor regarding applicable notice requirements under COBRA. The final regulations, which also include two model notices, contain a number of revisions from the proposed regulations that were published last year. The new rules will require employers and plan administrators to review and revise their current COBRA notices and summary plan descriptions for group health plans, as well as prepare COBRA procedures for certain purposes. The new rules require these changes to be made for plan years starting after November 26, 2004 which for calendar year plans will be January 1, 2005.