Short answer: Employers must report qualifying events, and plan administrators are responsible for sending COBRA notices. When the employer is also the plan administrator, the election notice must generally be sent within 44 days of the qualifying event.
COBRA notice responsibilities are shared between the employer and the plan administrator, and the specific duties depend on the type of notice and the employer’s plan structure.
The general (initial) COBRA notice must be provided to covered employees and their spouses within 90 days of enrollment in the group health plan. This notice explains COBRA rights and how continuation coverage works. It is typically sent by the plan administrator.
When a qualifying event occurs—such as termination of employment or a reduction in hours—the employer is responsible for notifying the plan administrator within 30 days of the event, unless the employer is also serving as the plan administrator.
After receiving notice of the qualifying event, the plan administrator has 14 days to send a COBRA election notice to each qualified beneficiary. If the employer is also the plan administrator, federal rules allow up to 44 days from the date of the qualifying event to send the election notice.
Failure to send required COBRA notices on time can expose employers and plan administrators to penalties and liability, which is why many employers use third-party COBRA administrators to manage these obligations.
Sources
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U.S. Department of Labor, FAQs on COBRA Continuation Health Coverage:
https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra -
U.S. Department of Labor, An Employer’s Guide to Group Health Continuation Coverage Under COBRA (Notice Requirements):
https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/publications/an-employers-guide-to-group-health-continuation-coverage-under-cobra.pdf
Content history
Originally published: March 27, 2025
Last reviewed: January 24, 2026