Our benefits broker and consulting firm provided the following opinion regarding the COBRA grace period even though it does not explicitly apply to non-ERISA, governmental employers. I think we are leaning toward providing this temporary relief but I am curious how other cities are handling this issue. "While the agencies fell short of making the rules regarding the outbreak period directly applicable to non-ERISA, governmental employers, the final rule includes a statement by HHS *encouraging* sponsors of non-federal governmental group health plans to extend similar timeframes and relief consistent with that afforded to ERISA-covered plans. Specifically, this language is provided from HHS: "HHS encourages plan sponsors of non-Federal governmental group health plans to provide relief similar to that specified in this notice to participants and beneficiaries, and encourages states and health insurance issuers offering coverage with a group health plan to enforce and operate, respectively, in a manner consistent with the relief provided in this notice." We wish the agencies had presented the rule in a more unequivocal manner, and it is possible that HHS will follow up with more formal guidance of its own. Nevertheless, due to this "encouragement" from HHS, we believe that non-ERISA plans should provide this temporary relief as well. Employers that desire to ignore this "encouragement" should consult with legal counsel." Thanks for any feedback. -- Blake E. Pennington Assistant City Attorney 113 W. Mountain St., Suite 302 Fayetteville, Arkansas 72701 Telephone: (479) 575-8313 bpennington@fayetteville-ar.gov<mailto:bpennington@fayetteville-ar.gov> [City attorney logo]<http://www.fayetteville-ar.gov/492/City-Attorney> [cid:image002.jpg@01D287AB.2928C1E0] <http://www.fayetteville-ar.gov/> Facebook<https://www.facebook.com/fayettevillearkansasgovernment> | Twitter<https://twitter.com/fyvgov> | Instagram<https://www.instagram.com/fyvgov/> | YouTube<http://www.youtube.com/user/cityoffayettevillear>