August 5, 2010

COBRA Subsidy Expired

The COBRA premium assistance subsidy, enacted as part of the American Recovery and Reinvestment Act (“ARRA”) in February, 2009, ended May 31, 2010, and has not been reinstated.  Therefore, individuals who are involuntarily terminated after May 31, 2010, do not qualify for the subsidy.  However, individuals who qualified for the subsidy on or before May 31, 2010 may continue to pay reduced premiums for the full subsidy period (15 months), as long as they are not eligible for another group health plan or Medicare.

At this point, plan sponsors should revert to their pre-ARRA COBRA notices and election forms, unless or until the subsidy is reinstated.  Following are links to DOL’s (pre-ARRA) COBRA notices and election forms:


The information contained in this Benefit Beat is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations.

As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this Benefit Beat is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service.

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