ARRA COBRA Subsidy Extension Update

Back in December 2009 we sent an email to you advising the ARRA COBRA subsidy bill (HR 3326) that would extend the subsidy coverage period would more than likely be signed into law. The President signed the bill on December 19, 2009 and below is the information I have been able to compile to date:

1. ARRA COBRA subsidy recipients whose eligibility was scheduled to end on December 31, 2009 will now be extended through February 28, 2010.

2. The subsidy period was extended from 9 months to 15 months for all assistance eligible individuals.

3.Those whose subsidy ended on November 30, 2009 (they reached the 9 months limit) now have a grace period of 60 days to pay their COBRA premium and extend their coverage.

4. Employers are to notify those who lost their subsidy on November 30, 2009 of their extended payment grace period (60 days).

5. Employers are to also notify anyone who was eligible as of October 31, 2009 or later of the subsidy changes.

I have been monitoring the Department of Labor web site for information and model notifications but have not found anything posted as of this writing.

There is also a possibility that the subsidy period will be extended to June 30, 2010 rather than February 28, 2010. We will advise everyone regarding this additional extension as soon as the information is available.