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DOL Releases Proposed Guidance Affecting COBRA Model Notices

On May 2, 2014, EBSA released an advanced copy of proposed rulemaking, which will be published in the May 7, 2014, Federal Register. The guidance amends notice requirements for COBRA so as to better align PPACA and COBRA notice requirements and to add information relating to special enrollment rights in the state health insurance exchanges.

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CMS Issues Guidance Related to COBRA Coverage and Exchange Eligibility

On April 21, 2014, CMS issued guidance, in the form of a frequently asked question (FAQ), clarifying how COBRA coverage impacts an individual's eligibility to enroll in the exchange and to receive a premium tax credit. As background, the open enrollment period for almost all exchanges ended March 31, 2014. Individuals may only enroll in the exchange midyear if they qualify for a special enrollment period due to a qualifying event. The FAQ clarifies that during the open enrollment period for the exchange, an individual who has voluntarily terminated his/her COBRA coverage (i.e., COBRA coverage has not been exhausted) will be eligible to enroll in a qualified health plan through the exchange.

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SB1339 Bay Area Commuter Benefits is Official

San Francisco recently took a major step in helping both its hard-working citizens and the environment. On March 26, 2014, the SB 1339 Bay Area Commuter Benefits Program became official. Now the Bay Area Air District and the Metropolitan Transportation Commission (MTC) will be working together with their regional Bay Area commuter policy, which mandates that all employers with 50 or more full-time employees, offer commuter benefits to both full-time workers and those that work at least 20 hours a week. Employers have until September 30, 2014, to comply with the SB 1339 Bay Area Commuter Benefits Program.

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