COBRA Notice Requirements: Every Notice, Who Sends It, and When

9/5/2026

COBRA requires a chain of notices. The plan sends a general notice when coverage begins. The employer or the qualified beneficiary tells the plan when a qualifying event happens. The plan then sends an election notice, or a notice that COBRA is unavailable. If coverage ends before its maximum period, the plan sends a notice of early termination. Each notice has its own sender, recipient, and deadline, and a missed link anywhere in the chain means the next notice goes out late.

The Notices at a Glance

Notice	From → To	Deadline
General (initial) notice	Plan administrator → covered employee and spouse	Within 90 days after plan coverage begins
Employer notice of qualifying event	Employer → plan administrator	Within 30 days of termination, reduction in hours, death, or Medicare entitlement
Qualified beneficiary notice of qualifying event	Employee or family member → plan administrator	Within 60 days of divorce, legal separation, or a child losing dependent status
Election notice	Plan administrator → each qualified beneficiary	Within 14 days after the administrator is notified (44 days after the event when the employer is the administrator)
Notice of unavailability	Plan administrator → individual who asked	Within the same period as an election notice
Disability extension notice	Qualified beneficiary → plan administrator	Within 60 days of the Social Security disability determination and before the 18 months end
Notice of early termination	Plan administrator → qualified beneficiary	As soon as practicable after deciding coverage will end early

General Notice

The general notice introduces COBRA rights before anyone needs them. It goes to each employee and spouse who becomes covered under the plan, within 90 days after their coverage begins. One notice addressed to both is enough if they live at the same address and the spouse's coverage began at the same time.

It must explain:

• What continuation coverage is
• The qualifying events
• The beneficiary's duty to notify the plan of divorce, legal separation, or loss of dependent status
• The plan's procedures for giving that notice
• Contact information for the plan

The Department of Labor publishes a model general notice. Using it, with the blanks filled in correctly, is the simplest way to cover the content rules.

Notices of Qualifying Events

From the employer. The employer must notify the plan administrator within 30 days after termination (other than for gross misconduct), reduction in hours, death, or Medicare entitlement. When a TPA is the administrator, this is the notice that gets lost most often. See common COBRA administration mistakes.

From the qualified beneficiary. For divorce, legal separation, or a child ceasing to be a dependent, the employee or family member must notify the plan within 60 days. The plan may set reasonable procedures, such as a form or required information. Those procedures must be described in the general notice and the summary plan description. If a plan never tells people about the procedures, it generally can't enforce them.

Beneficiaries must also give notice of a second qualifying event during an 18-month period, which can extend a spouse's or child's coverage to 36 months.

Election Notice

This is the core COBRA notice. The administrator has 14 days after receiving notice of a qualifying event to send it. When the employer is also the administrator, it has 44 days from the event, or from the loss of coverage if the plan measures from that date.

The election notice must include:

• The qualifying event and the date coverage will end
• Each qualified beneficiary by name or status
• The right to elect, and the fact that each beneficiary may elect independently
• The election deadline, which is at least 60 days
• The coverage available
• The maximum coverage period and how it can be extended or cut short
• The premium, due dates, and grace periods
• How to elect
• Other coverage options that may be available

The DOL also publishes a model election notice. Send it to every qualified beneficiary. Address a separate notice to a spouse or dependent known to live elsewhere.

Notice of Unavailability

When the administrator receives a notice of a qualifying event, a second qualifying event, or a disability determination, and decides the individual isn't entitled to COBRA or to the extension, it must say so in writing and explain why. The deadline is the same as for an election notice. Plans often skip this notice when they reject a late divorce notice or a request from someone who was never covered. That leaves the individual without a clear answer and leaves the plan without evidence that it decided anything.

Disability Extension Notice

A qualified beneficiary found disabled by the Social Security Administration at any time during the first 60 days of COBRA can extend coverage from 18 to 29 months. To get the extension, they must notify the plan within 60 days of the determination and before the original 18 months end. If Social Security later determines the person is no longer disabled, the beneficiary must notify the plan within 30 days.

Notice of Early Termination

If coverage ends before the maximum period, for example because premiums weren't paid or the beneficiary gained other group coverage, the administrator must send a notice as soon as practicable after deciding to end coverage. The notice gives the reason, the termination date, and any rights to other coverage, such as a conversion option. The permitted reasons and how to handle them are covered in early termination of COBRA coverage.

Other Notices Worth Building In

• Insufficient payment. If a premium is short by more than an insignificant amount, or the plan chooses not to accept a small shortfall, it must notify the beneficiary and allow 30 days to pay the difference before terminating.
• Plan changes and open enrollment. COBRA enrollees receive the same plan communications as active participants.

How to Deliver COBRA Notices

COBRA requires delivery by a method reasonably calculated to reach the individual. First-class mail to the last known address is the standard method. Certified mail isn't required, and a certified letter that goes unclaimed can leave you worse off than a first-class mailing with a proper log.

What matters is proof. Keep:

• A copy of each notice
• The address used
• The mailing date
• A mailing log or certificate of mailing

Electronic delivery is possible only when the DOL's electronic disclosure conditions are met.

Frequently Asked Questions

Do we have to use the DOL model notices?

No, but a model notice completed correctly is treated as good-faith compliance with the content requirements. A custom notice has to cover everything on its own.

Is one election notice enough for the whole family?

A single notice may go to the employee and spouse at one address, as long as it names each beneficiary's rights. Anyone known to live elsewhere should get their own notice.

What if the general notice was never sent?

Send it now, and review whether any beneficiary missed a notice deadline because they didn't know about it. The plan may be unable to enforce that deadline.

Does a notice have to go out when coverage ends at the maximum period?

The early termination notice is required only when coverage ends before the maximum. Many plans send an end-of-coverage letter anyway, which is good practice.

Related Reading and Training

For the full workflow, see the COBRA administration process. To check whether the rules apply to you, see which employers are subject to COBRA. Notice drafting and delivery are covered in the COBRA training and certification program, and terms are defined in the COBRA glossary.