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COBRA Notice and Disclosure Rules
Earlier this year, the US Department of Labor (DOL) published proposed regulations updating the notice and disclosure requirements applicable to health care continuation coverage under the Consolidated Omnibus Budget Reconciliation Act (COBRA). These proposed regulations update model notices, give disclosure guidance, and establish two new required COBRA notices. The proposed regulations were originally effective for plan years beginning on or after January 1, 2004. However, in September, the DOL announced a delayed effective date in order to allow employers and plan administrators time to comply with the new requirements. The effective date is now 6 months after the DOL's adoption of the final rules to implement the administrative changes required by the new rules. The DOL expects to issue final rules in early 2004.
Background
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The DOJ's Corporate Enforcement Policy: One Year Later
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