Status Update on DOL’s Expansion of Electronic Disclosure

In May 2011, Travis blogged about a new “Request for Information” by the Department of Labor regarding the possible expansion of electronic disclosure by employee benefit plans, including COBRA disclosures.

On September 13, 2011, the Employee Benefits Security Administration (EBSA) followed through on the Request and issued interim e-disclosure policies for participant-fee disclosure regulations. While this policy does not directly affect COBRA administration, it may be a sign for what might be coming.


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Update from the Department of Labor – COBRA Continuation Coverage

The Employee Benefits Security Administration (EBSA) recently updated the DOL website to address the expiration of the COBRA continuation coverage assistance under the American Recovery and Reinvestment Act (ARRA). The update modified the introductory paragraph to address the ARRA subsidy expiration on August 31, 2011 and added a new Question/Answer to the “Frequently Asked Questions” page to discuss situations where the 15-month ARRA subsidy may extend beyond the general expiration date of August 31, 2011.


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Possible Expansion of the Permissible Use of Electronic Disclosure

In April 2011, the Department of Labor (DOL) released a Request for Information asking the employee benefits community to comment on the possible expansion of the permissible use of electronic disclosure by employee benefit plans.

More specifically, the DOL is now exploring whether and how to expand or modify the current standards under ERISA applicable to the electronic distribution of required plan disclosures that were first established in April, 2002.


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New Releases of both TravisCobra and WebCOBRA.com with DOD COBRA Changes are Now Available

Users of both TravisCobra and WebCOBRA.com are now able to use new releases of these systems reflecting the changes to the COBRA law enacted December 22nd as part of the Department of Defense Appropriation Act 2010.


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Notifying Enrolled COBRA QBs of ARRA

Now COBRA Administrators have re-notified QBs of their right to re-enroll in COBRA effective 3/1/2009, the attention turns to enrolled QBs. We’ll divide those into two groups, and discuss how we recommend you notify them of ARRA, as well as give alternatives that you can choose from.


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