I have a very old COBRA training book. I know some changes took place with this regulation. What is the time requirement now for the issuance of the Initial COBRA Notification Letter?
You can put the initial notice in your SPD, but its better to send a separate notice. Remember that employees' spouses must get a continuation-coverage notice, too. You can't hand the notice to the employee telling them that they should give it to their spouse. That's not legal under COBRA. If you send a separate notice you can include the spouse.
Initial notice can go to in the SPD and can go to employees only, the one exception to getting the notice to spouses. Otherwise, notices must go to ee's & spouses, and the burden of proof on delivery is that the method of delivery you use must satisfy a reasonable expectation that delivery is/was made. Therefore, having copies available for employees to pick up in a common area and rely on the worker to get the info home to spouse is not acceptable.
Great place to get current info on COBRA and most other federal employment laws (FMLA, FLSA, etc) is the U.S. Department of Labor Website [url]www.dol.gov[/url]. The info is updated as the laws change and it is FREE.
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