Have you noticed how much notice issues regarding federal continuation coverage seem to be cropping up everywhere—such as in the news, the courts, and the administrative agencies? Well, the latest matter involves part of the regular evaluation of paperwork requirements conducted by the Internal Revenue Service (IRS).
In a December 7, 2020 notice published in the Federal Register (85 Fed. Reg. 78935), the IRS requested comments on notice requirements for continuation coverage applicable to group health plans under the Consolidated Omnibus Budget Reconciliation Act (COBRA).
By way of background, COBRA’s regulatory jurisdiction is divided primarily between