Compliance Date January 01, 2011
(Please remember your COBRA participants)
The interim final regulations extending dependent coverage to age 26 provide transitional relief for a child whose coverage ended, or who was denied coverage (or was not eligible for coverage) under a group health plan or health insurance coverage because, under the terms of the plan of coverage, the availability of dependent coverage of children ended before the attainment age of 26. The regulations require a plan or issuer to give such a child an opportunity to enroll that continues for at least 30 days (including written notice of the opportunity to enroll), regardless of whether the plan or coverage offers an open enrollment period and regardless of when any open enrollment might otherwise occur. This enrollment opportunity (including the written notice) must be provided not later than the first day of the first plan year beginning on or after September 23, 2010. The notice may be included with other enrollment materials that a plan distributes, provided the statement is prominent. Enrollment must be effective as of the first day of the first plan year beginning on or after September 23, 1010.
www.dol.gov/ebsa/dependentsmodelnotice.doc
The following model language can be used to satisfy the notification requirement. Please feel free to copy and paste the following language.
Individuals whose coverage ended, or who were denied coverage (or were not eligible for coverage), because the availability of dependent coverage of children ended before attainment of age 26 are eligible to enroll in (current group health plan or insurance coverage.) Individuals may requst enrollment for such children for 30 days from the date of notice. Enrollment will be effective retroactively to (date that is the first day of the first plan year beginning on or after September 23, 2010). For more information contact your current plan administrator or issuer.