Test Your COBRA Compliance Program
.
YES
NO
NOT SURE
1.
 Do you have a COBRA procedures manual?
2.

 Have your COBRA policies and materials been revised for
 legal compliance?

3.

 Do you provide written notification of COBRA rights to each
 newly-covered employee and each spouse?

4.

 Do you send your notices with certificates of mailing addressed  
 to both the employee and the spouse with a separate notice sent to  spouses living at a different address?

5.
 Do you allow independent elections among qualified beneficiaries?
6.
 Do you provide a 45 day grace period to pay the initial premium?
7.
 Are all COBRA notices properly worded in accordance with
 DOL and COBRA regulations?
8.
 Is the person responsible for COBRA within your company
 specifically trained to do so?
9.
 Have you changed the language in your notices to comply with
 recently issued final regulatins and newly proposed regulations?
10.
 Do you regularly review your compliance program for accuracy
 and necessary revision?

Rate your compliance program.
Apply the number of 'yes' anwsers to the following scale.

9-10
EXCELLENT
 Continue to monitor your program; make minor adjustments
 when appropriate.
7-8
GOOD
 Gaps in your program exist. Look into filling those gaps.
5-6
FAIR
 Your program is incomplete. Liability exists.
 Seek assistance to improve your program.
0-4
POOR
 Your program needs work. Significant liabillity exists. Seek help.