Under what circumstance does the employer not have to send itself a qualifying event notice?

• A. The employer is the administrator of its own plan
• B. The employee has elected COBRA
• C. The plan is terminated
• D. The qualifying event is death of the employee

Answer: (A)

The key idea is who is responsible for COBRA notices. After a qualifying event, the plan administrator must send a notice informing qualified beneficiaries about their COBRA rights. If the employer is the administrator of its own plan, there isn’t a separate external party to notify—the same entity handles the plan’s COBRA communications. So, in that circumstance, the employer does not have to send a qualifying event notice to itself because the notice duties are performed internally by the plan administrator (the employer) for the benefits holders.

The other situations don’t create an exception to this rule. Elections, plan termination, or the death of an employee all relate to COBRA rights and timing, but they don’t remove the obligation to provide the initial COBRA rights notice to qualified beneficiaries when a qualifying event occurs.