Initial Rights Notice (IRN) (aka General Notice)

Group health plans must give each employee and each spouse of an employee who becomes covered under the plan a general notice describing COBRA rights. The general notice must be provided within the first 90 days of coverage. Group health plans can satisfy this requirement by including the general notice in the plan’s SPD and giving the SPD to the employee and to the spouse within this time limit.

The general notice must include:
The name of the plan and the name, address, and telephone number of someone whom the employee and spousecan contact for more information on COBRA and the plan;

• A general description of the continuation coverage provided under the plan;
• An explanation of what qualified beneficiaries must do to notify the plan of qualifying events or disabilities;
• An explanation of the importance of keeping the plan administrator informed of addresses of the participants andbeneficiaries; and
• A statement that the general notice does not fully describe COBRA or the plan and that more completeinformation is available from the plan administrator and in the SPD.
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The Department of Labor has developed a model general notice that single-employer group health plans may use to satisfy the general notice requirement. It is available at dol.gov/ebsa. In order to use this model general notice properly, the plan administrator must complete it by filling in the blanks with the appropriate plan information. Use of the model general notice, appropriately completed, will be considered by the Department to be good faith compliance with the general notice content requirements of COBRA.

Employers should consider the costly law-suits of the past pertaining to improper IRN notification, and it is recommended that all Initial Rights Notifications are documented, including proof of mailing. 

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