Q.- An employee received a COBRA Initial Rights Notice when he first enrolled in our health plan. He is now adding his 15 year old son to coverage. Do we have to send the son a COBRA Initial Rights Notice?
A.- No. The COBRA Initial Rights Notice must be provided to the employee and spouse covered under the health plan. It does not have to be provided to a child, regardless of the child's age. If a spouse is later added to an employee’s coverage, the spouse will have to receive a COBRA Initial Rights Notice when added. The same does not hold true for the addition of a child.