Ask most HR teams about COBRA and they’ll describe termination packets: election forms, premium quotes, 60-day election windows. Good. Necessary. Incomplete.
Federal COBRA also requires a general notice — often called the initial notice — explaining COBRA rights when someone first becomes covered under a group health plan. For calendar-year plans, think in terms of 90 days from the coverage start date. Miss it and you’ve created a technical failure even if your qualifying-event process is pristine.
Who should get it
Covered employees and covered spouses. Domestic partners and other dependents may need plan-specific handling depending on how the plan defines qualified beneficiaries, but the employee/spouse core is not optional for COBRA-subject plans.
Why February is a good time to audit
January new hires and January 1 open-enrollment adds are now inside (or approaching) that 90-day window. Pull a sample:
- New medical/dental/vision enrollments effective 1/1 or later.
- Confirm the initial notice date in your COBRA administrator’s system (or your mail log).
- Check that FSA/HRA plans subject to COBRA aren’t left out of the notice package where required.
HSA side note
HSAs themselves aren’t COBRA-continued account balances in the group-plan sense, but the HDHP usually is. Don’t confuse “the account is portable” with “we can skip COBRA on the insurance.”
If you outsource COBRA — smart for most employers — your job is still oversight. Administrators run on the data you send.