On June 21, 2016, the Departments of Labor, Health and Human Services, and the Treasury (collectively, the “Departments”) issued the 32nd Affordable Care Act (“ACA”) FAQ describing information that may be appropriate to include with COBRA notices. Many wondered if it were appropriate to provide information and if so, what kind of information could be provided about the Health Insurance Marketplaces/Exchanges (“Marketplaces”) so that COBRA-eligible individuals could consider health coverage alternatives available through the Marketplaces and possibly investigate whether they may be eligible for premium tax credits and cost-sharing reductions. The current model COBRA notice includes some information to help make qualified beneficiaries aware of other coverage options available in the Marketplaces, but that information is limited. Note that employers also should send a Notice of Coverage Options to all employees at time of hire. That document describes Marketplace options as well.
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