As April 1 approaches, don’t let key compliance deadlines slip through the cracks! To stay compliant with COBRA and SPD requirements, make sure you’ve completed the following:
- Provide COBRA General Notice to participants newly enrolled at the beginning of the plan year.
Per COBRA, group health plans are required to provide a written General Notice of COBRA Rights to each covered employee and their spouse (if applicable) within 90 days after the employee’s health plan coverage begins. This also applies to any new dependents added to the plan after the employee’s initial enrollment date, with the notice required within 90 days of the dependent’s coverage effective date. The Department of Labor (DOL) has a COBRA Model General Notice that can be used by group health plans to meet their notice obligations. - Provide Summary Plan Description (SPD) to participants newly enrolled at the beginning of the plan year.
(This deadline only applies to group health plans that are subject to ERISA.)
For group health plans subject to the Employee Retirement Income Security Act (ERISA), employers must provide a Summary Plan Description (SPD) to employees within 90 days of their initial enrollment in the health plan. The SPD must be written clearly and comprehensively to ensure employees understand their rights and obligations under the plan. Employers may include the SPD as part of the enrollment materials to simplify the process.
Additionally, an updated SPD must be provided to participants at least every five years if material modifications have been made. If no changes have been made, the SPD must be updated and distributed at least every 10 years.
Don’t wait until the deadline—review your compliance status now to avoid penalties. If you have any questions or need assistance, feel free to reach out.