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COBRA General (Initial) Notice

Explains continuation coverage rights, qualifying events, and election rules. Provide to covered employees and spouses within 90 days of coverage beginning.

Companies Eligible

Employers with 20+ employees, for every group health plan they sponsor.

Count employees on more than half of the typical business days in the prior calendar year; part-time employees count as fractions. Covers medical, dental, vision, prescription drug, HRA, health FSA and any EAP that provides medical care. Church plans and federal plans are exempt. Under 20 employees, federal COBRA does not apply and the state continuation law governs instead.

What it is

The DOL model general notice tells covered employees and spouses that they can continue coverage after a qualifying event, how to notify the plan of a divorce or a child losing dependent status, and how election and payment work. It is the first of the COBRA notices and the only one tied to enrollment rather than to an event.

What needs to be done

  • When: Within 90 days after the employee's (or spouse's) coverage under the plan begins. Including it in an SPD delivered inside that window also satisfies the rule.
  • To whom: The covered employee and any covered spouse. One notice mailed to the home addressed to both is fine when they live at the same address; a spouse who enrolls later gets a separate notice.
  • Who performs: The COBRA administrator (TPA) when the service agreement covers the general notice; check the COBRA Administrator on the Company record. Otherwise the employer sends it.
  • Customize: Plan name, plan administrator name, address and phone, COBRA administrator contact, and how to notify the plan of divorce and dependent events.
  • Deliver: First-class mail to the last known address. Handing it to the employee does not cover the spouse. Paper by hand or first-class mail to the home always works. Electronic delivery meets the DOL safe harbor only for employees who use a computer where they work as an integral part of their duties; anyone else (spouses, former employees, employees without work computers) has to consent in advance.
  • Keep: A dated copy and a mailing log for each employee — the general notice is the first thing a COBRA dispute asks for.

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