Are plan sponsors required to mail an annual COBRA notice to employees? We provide COBRA information upon a qualifying event and also in the SPD's but the SPD is not necessarily updated annually. I understand that the Women's Cancer Rights must be mailed annually, could we include the COBRA notice with this or does it have to be mailed separately if an annual COBRA notice is required?

I believe the regs say you must provide an initial notice. When the IRS issued multiple changes in 2000 we updated our COBRA notices and sent them out to everyone for whom we administer COBRA. (we're a TPA). I hesitated to do this because I didn't want people to think their jobs were in jeopardy....we drafted an explanatory cover letter to explain the reason they were receiving a new notice. If you want to send another, go ahead. As long as it is distinct from the WHCRA notice, I don't see why they can't be mailed together.