The DOL has finally published model notices concerning the extended COBRA subsidy. The notices are 'Updated General Notice,' 'Premium Assistance Extension Notice,' and 'Updated Alternative Notice.' ARRA, as amended by the Department of Defense Appropriation Act, 2010 (2010 DOD Act--yes the COBRA subsidy was passed as part of a defense bill!), mandates that plans notify certain current and former participants and beneficiaries about the premium reduction. The Department created model notices to help plans and individuals comply with these requirements. Each model notice is designed for a particular group of qualified beneficiaries and contains information to help satisfy ARRA's notice provisions, including those added by the 2010 DOD Act.
The notices are available now on the DOL website.
Separately, the DOL announced the publication of a final rule to protect employee contributions deposited to small pension and welfare benefit plans with fewer than 100 participants: the safe harbor is 7 days.
Currently, employers of all sizes must transmit employee contributions to pension plans as soon as they can reasonably be segregated from the general assets of the employer, but no later than the 15th business day of the month following the month in which contributions are received or withheld by the employer. The latest date for forwarding participant contributions to health plans is 90 days from the date on which such amounts are received or withheld by the employer.
The new rule is published in the January 14, 2010 Federal Register.
