Q.- We know there is a penalty for not providing a notice when someone has a COBRA qualifying event. We just learned that there is a requirement to give a notice when someone is first eligible for health coverage- long before COBRA would be a consideration. Is there a penalty for not providing this notice?

A.- Yes. The failure to provide any required COBRA notice, including the COBRA Initial Rights Notice, can result in penalties of up to $110 per day for each notice that is not sent. The $110 per day penalty applies to the initial rights notice just like it would apply to the qualifying events notice.