If a plan fails to establish reasonable procedures, how can the employee or qualified beneficiary fulfill their obligation to notify the plan administrator?

• A. By providing oral or written notice to the person or department that handles employee benefit issues for the employer
• B. By contacting the SSA directly
• C. By filing a claim with the insurer
• D. By submitting a tax form to the IRS

Answer: (A)

When a plan hasn’t set up reasonable procedures for notifying COBRA events, the employee or qualified beneficiary fulfills the obligation by giving oral or written notice to the person or department that handles employee benefit issues for the employer. This internal contact is the one responsible for COBRA administration, so directing the notice there ensures the plan administrator learns of the event and can offer continuation coverage accordingly. Searching with the SSA, filing claims with the insurer, or sending tax forms to the IRS doesn’t satisfy this COBRA notice requirement, as those pathways aren’t the designated channel for notifying the plan administrator about COBRA events.