For your reference, here’s what JD Supra contributors are writing about President Obama’s December, 2009, extension of the COBRA premium subsidy program.
JD Supra Employment Law Update: The COBRA Subsidy Extension
While the rest of us were busy putting the final touches on our Christmas packages, on December 19, 2009, President Obama signed into law the Department of Defense Appropriations Act for Fiscal Year 2010 (“DDAA”). This law extends both the eligibility period and the length of the COBRA premium subsidy created by the American Recovery and Reinvestment Act of 2009 (“ARRA”)…
…the 2010 DOD Act extended the COBRA premium reduction eligibility period for two months, through February 28, 2010 and increased the maximum period for receiving the subsidy from 9 to 15 months.
The Department of Labor has just published the new model notice to be used for COBRA. The notice must be sent to all eligible individuals by February 17, 2010…
The Act also includes a period for the retroactive payment of premiums for individuals who were entitled to the subsidy but whose subsidy period expired on November 30 and who failed to pay their premium for December coverage. The retroactive period is 60 days, commencing with the enactment of the provision or, if later, 30 days after provision of notice…
Not all COBRA “qualified beneficiaries” are entitled to take advantage of the subsidy. Rather, a qualified beneficiary is eligible if he or she is an “Assistance Eligible Individual” (AEI), defined as a COBRA qualified beneficiary who becomes eligible for COBRA, during the period beginning September 1, 2008 and ending February 28, 2010, due to the involuntary termination of employment of the covered employee…
– Earlier COBRA Updates & Related Commentary:
- Much Anticipated New Model COBRA Notices Released – by Williams Kastner
- Questions and Answers Regarding COBRA Subsidy (July, 2009) – by McAfee & Taft
- DOL Issues Model COBRA Notices to Reflect Changes Mandated by the Stimulus Package (March, 2009) – Foley Hoag LLP
- COBRA Changes Effective Immediately (Feb, 2009) – Williams Kastner
- COBRA Subsidy in New Stimulus Law Adds Administrative and Notice Requirements for Employers (Feb, 2009) – McAfee & Taft