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Proposed regulations for COBRA

cowboycowboy 11 Posts
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Being aware of the PROPOSED regulations implementing the notice requirements for COBRA, is anyone aware of a date for implementation? Last I read was that DOL PROPOSED to make the regulations, in their final form, effective and applicable as of the first plan year that occurs on or after January 1, 2004.
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  • SueSue 64 Posts
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    My understanding is the DOL wants employers to use the new forms and notices right now. The remainder of the proposed regulations involves documenting procedures - which does not have a set date.

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  • Scott RuthScott Ruth 65 Posts
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    The proposed regulations did state a proposed effective date of plans years on or after 1/1/2004, but this date has not been finalized. Nevertheless, I agree with Sue that the DOL wants employers to start following the proposed rules ASAP. Doing so is generally "good faith compliance." In particular, if you are still using the 1986 model notices you should switch to the ones in the proposed regulations or similar, modified to fit your situation.


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