In addition to sending COBRA letters to terminated employees and covered spouses, must COBRA letters be sent to covered children also?

If the children are minors, notification to the employee and spouse is suffucient. A parent must make the selection for a minor child.
If the dependent is not a minor, it's recomended to send notice to the child. For instance, some coverage ends for dependents at age 23 in which case the notice should go directly to the dependent even if the dependent is living with the parents.

If minor dependent children do not live with the employee, notice for the children should go to the employee and parent with custody, if known just to be safe.

You may want to look at DOL Opinion letter
99-14A. DOL now states that if spouse and dependents live at the same address as the employee, then only one notice needs to be sent. However, notice must explain that spouse and dependents have election rights separate and apart from those of the employee. To use a single notice, it must "clearly identify the qualified beneficiaries covered by the notice."

This is a DOL pronouncement, IRS also audits for COBRA compliance and I am not sure whether they agree with this single notice position.

Under 606© of ERISA notice to a spouse qualifies as notice to beneficiaries living with the spouse.

Of course if you know that a spouse or dependent lives at another address, they must get a separate notice.


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