Notice Requirements of the Health Care Continuation Coverage Provisions

Forms and Documents

Document	Type	Status	Availability
1210-0123 COBRA SS 12.22.25.docx	Supporting Statement A	Uploaded 2025-12-22	Available

IC Document Collections

IC ID	Collection	Type	Status	Form
13504	Notice Requirements of the Health Care Continuation Coverage Provisions	Other-COBRA Model General Notice	Modified

ICR Details

OMB Control No: 1210-0123	ICR Reference No: 202508-1210-007
Status: Received in OIRA	Previous ICR Reference No: 202210-1210-001
Agency/Subagency: DOL/EBSA	Agency Tracking No:
Title: Notice Requirements of the Health Care Continuation Coverage Provisions
Type of Information Collection: Extension without change of a currently approved collection	Common Form ICR:  No
Type of Review Request: Regular	Date Submitted to OIRA: 01/12/2026

	Requested	Previously Approved
Expiration Date	36 Months From Approved	06/30/2026
Responses	24,351,126	26,890,373
Time Burden (Hours)	524,890	490,857
Cost Burden (Dollars)	19,237,389	16,403,128

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Abstract: The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) provides that under certain circumstances participants and beneficiaries of group health plans that satisfy the definition of “qualified beneficiaries” under COBRA may elect to continue group health coverage temporarily following events known as “qualifying events” that would otherwise result in loss of coverage. Under the regulatory guidelines, plan administrators are required to distribute notices: a general notice to be distributed to all participants in group health plans subject to COBRA; an employer notice that must be completed by the employer upon the occurrence of a qualifying event; a notice and election form to be sent to a participant upon the occurrence of a qualifying event that might cause the participant to lose group health coverage; an employee notice that may be completed by a qualified beneficiary upon the occurrence of certain qualifying events such as divorce or disability; and, two other notices, one of early termination and the other a notice of unavailability. Also included in the ICR are two model notices that the Department believes will help reduce costs for service providers in preparing and delivering notices to comply with the regulations.

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Authorizing Statute(s): US Code: 29 USC 1168 Name of Law: Employee Retirement Income Security Act
   US Code: 29 USC 1166 Name of Law: Employee Retirement Income Security Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	90 FR 30984	07/11/2025
30-day Notice:	Federal Register Citation:	Citation Date:
	91 FR 1199	01/12/2026
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Notice Requirements of the Health Care Continuation Coverage Provisions

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	24,351,126	26,890,373	0	0	-2,539,247	0
Annual Time Burden (Hours)	524,890	490,857	0	0	34,033	0
Annual Cost Burden (Dollars)	19,237,389	16,403,128	0	0	2,834,261	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: There are no program changes for this submission. The increases in the cost burden estimates are due to a decrease in the number of individuals in COBRA eligible plans, labor cost inflation, and increased postage costs resulting from inflation. As a result, the number of responses has decreased 2,539,247 responses, the hour burden has increased by 34,033 hours, and the cost burden has increased by $2,834,261. While the decline in responses is a result of fewer general notices being sent, the hour and cost burdens have increased due to an increase in the number of termination notices and plan administrator election notices, as well as an increase in the cost of postage to mail the notices.

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Annual Cost to Federal Government: $0

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Yes

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 01/12/2026

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