ICHRA COBRA PACKET COMPLETION AND DELIVERY GUIDE
Prepared November 6, 2026

These are reusable employer templates, not completed notices. They retain the full participant-facing DOL general and election model content with ICHRA-specific supplements. The election form and payment information remain included. Complete all bracketed fields, select applicable alternatives, and remove inapplicable administrator prompts before delivery. The original DOL models are included for reference; they do not replace the customized notices.

1. Confirm applicability. Federal COBRA generally covers employer group health plans where the employer had at least 20 employees on more than 50 percent of typical business days in the preceding calendar year. Apply aggregation and part-time counting rules and any statutory exclusions. Do not use ACA ALE status as the COBRA test. Evaluate state continuation separately.
2. Identify the employer legal name, plan name, plan administrator, COBRA administrator, mailing address, phone and any permitted electronic submission channel. The ICHRA Shop or ChoiceBenefits branding does not make the agency the plan administrator.
3. General notice: complete the plan-specific qualifying-event and disability-notification procedures and provide the notice to the covered employee and covered spouse generally within the first 90 days of coverage. Preserve the delivery record.
4. Election notice: record each qualified beneficiary, qualifying event, event date, coverage-loss date, continuation start date and maximum end date. Each qualified beneficiary has an independent election right. Send separate notices to known separate addresses.
5. Election notice timing: employer notice to the administrator is generally due within 30 days for employer-reportable events; the administrator generally has 14 days after receiving notice. Where the employer is also administrator, the combined deadline is generally 44 days, with the loss-of-coverage rule applied when appropriate. Calculate the applicable deadline for the actual event and plan terms.
6. Allow at least 60 days to elect measured from the later of the notice date or the coverage-loss date. Specify the actual return deadline and delivery method. The initial payment deadline is at least 45 days after election; periodic payments have at least a 30-day grace period. Complete the payment address, due dates and any longer plan periods. Account for any relief actually applicable to the event.
7. Describe the continued ICHRA reimbursement amount, eligible expenses, family coverage, carryover, claims substantiation, claims runout and benefit changes applicable to similarly situated active participants. Do not promise continued employer funding at no charge.
8. Obtain the plan administrator's properly calculated applicable COBRA premium for each option. Do not automatically use 102 percent of the reimbursement allowance, the individual insurance premium, or a PEPM administration fee. Standard charges generally cannot exceed 102 percent of the applicable premium; special disability-extension rules may apply. Record any employer subsidy separately.
9. Explain that individual insurance continues separately, subject to the policy terms and payment. ICHRA continuation requires qualifying individual coverage or permitted Medicare coverage and continued substantiation. Individual carrier premium obligations remain separate from the ICHRA COBRA charge.
10. Review Marketplace and Medicare language for the beneficiary. An accepted ICHRA prevents a premium tax credit for the same person's covered months. A former employee can decline the offer and may qualify for a tax credit; reduction-in-hours cases involving current employees require the applicable affordability analysis. Do not suggest ICHRA plus individual insurance automatically preserves a Medicare Part B enrollment period.
11. Complete disability and second-event notification procedures, including recipient, required documentation and applicable deadlines. The election notice must reflect the actual plan's extension rules.
12. Before release, search the notice for '[' and ']' and resolve every field and drafting choice. Check that the benefit description, COBRA rate, payment schedule, dates and named beneficiaries agree throughout. Keep a copy of the completed notice, mailing or compliant electronic delivery evidence, election and payments. This download does not send a notice or enroll anyone in COBRA.

OFFICIAL SOURCES
DOL general model: https://www.dol.gov/sites/dolgov/files/EBSA/laws-and-regulations/laws/cobra/model-general-notice.docx
DOL election model: https://www.dol.gov/sites/dolgov/files/EBSA/laws-and-regulations/laws/cobra/model-election-notice.docx
DOL employer guide: https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/publications/an-employers-guide-to-group-health-continuation-coverage-under-cobra
CMS ICHRA COBRA overview: https://www.cms.gov/sites/default/files/2021-01/Overview%20of%20New%20Health%20Reimbursement%20Arrangements%20Part%20Two%20Slides.pdf
CMS ICHRA notice resources: https://www.cms.gov/marketplace/private-health-insurance/health-reimbursement-arrangements
IRS HRA FAQs: https://www.irs.gov/pub/newsroom/health_reimbursement_arrangements_faqs.pdf

The regular annual ICHRA notice is separate from both COBRA notices. These templates must be completed for the actual plan; no blank template guarantees compliance with all content, timing and delivery requirements.