In a published opinion letter the Pension and Welfare Benefits Administration has said that a single COBRA election notice may be sent to all beneficiaries who reside at a single address. Former employees, their spouses and dependents may all be COBRA beneficiaries in certain cases, and each beneficiary is entitled to make an independent COBRA election. Until now it has been clear only that dependents and another beneficiary residing at a single address could be sent a single notice, but now it is clear that the employee, his or her spouse and all dependents may be sent one election notice if they have a common address. The single notice, however, must be addressed to each of the COBRA beneficiaries and clearly inform them of their individual election rights.
Many employers' COBRA election notices are maintained on separate forms for employees, spouses and dependents because different events and coverage periods apply to the different COBRA beneficiaries. Employers who maintain separate forms must remember to send all of the types of forms applicable to all of the addressees. We also recommend that the names of all of the COBRA beneficiaries appear as addressees.