The Department of Labor, through the Employee Benefits Security Administration (EBSA), issued proposed regulations that implement the notice requirements under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). 68 Fed. Reg. 31832 (May 28, 2003). Groom Law Group drafted comments on behalf of the American Benefits Council recommending that the Department of Labor modify proposed COBRA regulations to eliminate provisions that unnecessarily burden group health plan sponsors by creating additional cost and exposure to liability.