No, the new COBRA notice does not need to distributed by March 1st; March 1st is simply the effective date of ARRA. The employer has 60 days after the effective date, which would be approximately May 31st. And HHS is required to have a model notice available within 30 days of the effective date.
Marlene H. Bowen, LUTCF, RHU
MEHRINGER & ASSOCIATES
Evansville, IN
812-449-9782
Marlene@MehringerAssociates.com