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Susan Bock
1) Do the final and proposed COBRA regulations issued in February 1999 make similar changes to continuation coverage for plans sponsored by government employers?
2) Are the notice requirements for continuation coverage for government employers "exactly" the same as COBRA? That is, if a government employer uses the model notice provided by COBRA, will that meet the minimum requirements of the Public Health Service Act? Does the "model" notice provide more than the minimum necessary for government employers?
BENEFISH
Yes, new regulations apply to state and local government employers subject to continuation of coverage requirements under the Public Health Service Act. The "model" notice provided by the DOL is just that-a model. You can modify it as you see fit for your situation, but I don't know of any information provided by the model notice that does not apply to state and local government employers.

You may want to contact BMI Audit Services at www.cobraaudit.com for help in this area. They have prepared excellent notices and election materials for our company and possess a wealth of technical knowledge.
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