Once a hire clears screening, the benefit notices clock starts running.
After an offer becomes final, the new hire needs plan enrollment materials and several required notices. Keeping screening paperwork separate from benefit paperwork protects privacy and keeps both processes clean.
What the rule says.
General education only, without legal advice. Notice and plan-document rules change, so confirm the current text.
General COBRA Notice
The plan administrator must give each covered employee and spouse the general COBRA notice within 90 days after coverage begins.
Keep Screening Records Separate
Screening reports are consumer reports with their own confidentiality and disposal expectations, so they should not sit with enrollment files.
Other Plan Notices
A group health plan has additional notices, including special enrollment rights, so build a checklist.
How it plays out.
Build one onboarding checklist that shows the order: final offer, screening cleared, enrollment materials, notices, signed acknowledgments.
Give a new hire a clear enrollment deadline and explain who to contact. Missing the window can mean waiting for open enrollment.
Store medical forms and screening results in their own restricted files rather than with ordinary personnel papers. This is an overview for planning and is not advice on your particular files.
Where this shows up in your plan.
Enrollment Window
State the deadline to elect coverage after eligibility begins, as set in the plan document.
COBRA General Notice
Deliver the general notice with the enrollment packet or within 90 days.
Plan Document Access
Make sure the summary plan description is available or delivered on time.
Setting it up.
Confirm the offer is final and screening is complete.
Send enrollment materials with a deadline.
Deliver the general COBRA notice and other plan notices.
Collect signed acknowledgments.
File screening and benefit records separately.
Mistakes to avoid.
Do not send benefit materials before the offer is final.
Do not mix medical or screening records in the enrollment file.
Do not forget the general COBRA notice.
Do not leave the enrollment deadline unstated.
Other rules employers work with.
COBRA Guide for Michigan Employers
What the general notice does.
Required Workplace and Benefit Notices
A fuller checklist.
Employer Screening and FCRA Guide
The main screening guide that this onboarding page follows.
Laws and Rules Referenced
General COBRA notice, 29 CFR 2590.606-1 — General notice timing.
FCRA employer-use section, 15 U.S.C. 1681b — Limits on how a consumer report may be used once it is in hand.
Section 104 of ERISA, 29 U.S.C. 1024 — The duty to provide participants with the summary plan description.
Quick answers.
Common onboarding paperwork questions after a clean screen, each linking to a more complete guide.
When must the COBRA general notice go out?
Within 90 days after coverage begins.
Can screening results go in the benefits file?
It is better to keep them separate and confidential.
What if a new hire misses the enrollment window?
Coverage may wait until open enrollment unless a special enrollment event applies.
More guides in this series.
FCRA Disclosure and Authorization Requirements for Michigan Employers
A companion guide in the same series.
FCRA Pre-Adverse Action Notices Before Rescinding a Job Offer
A companion guide in the same series.
FCRA Adverse Action Notice Content Requirements for Employers
A companion guide in the same series.
Conditional Offer Letters and Background Check Timing in Michigan
A companion guide in the same series.
Background Checks for Benefit Plan Fiduciaries and ERISA Bonding
A companion guide in the same series.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →