Category Archives: COBRA

Senate Passes, President Signs, One Month Unemployment Benefits Extension

The bill, held up this week in the Senate, passed the Senate last night and was signed by the President.

The COBRA Premium Subsidy extension is included in the bill.  The measure is seen as a short-term fix, allowing lawmakers time to debate a longer extension to the programs.

Stay tuned!

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Extending the COBRA Premium Subsidy Extension (No, it’s not inadvertently redundant.)

The original COBRA premium subsidy extension, passed in December 2009, extended the original eligibility period for involuntarily termed employees. The original cutoff date, December 31, 2009, moved to February 28, 2010.

With February 28th  just four days away, a NEW extension for COBRA premium subsidy eligibility has not yet been passed.  In fact, reference to such an extension was actually stripped from the jobs bill passed by the Senate today.  

However, the AP reports that with the jobs bill now on its way to the House, Harry Reid now wants to extend the COBRA extension  (as well as unemployment benefits) before February 28th. 

Reid is reported to be considering a two step process:

     1) An initial 30 day extension.
     2) A follow on,  longer term extension, possibly to the end of December.

Another scenario, of course, is “no further extension”…an unlikely outcome, in our view.

We will keep you informed …

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Stay Tuned – Further Extension to the COBRA Subsidy Likely

Among the legislation delayed by the snowfall in Washington is another possible extension to the COBRA subsidy.

The initial changes made last year were: 

  • The last the end date of eligibility for the ARRA subsidy was extended from December 31, 2009, to February 28, 2010.
  •  The ARRA premium Subsidy increased from nine months to the current 15 months. 

Now, at least two different sets of extensions are being considered: 

 1)      The Administration’s proposed federal budget for fiscal year 2011 includes a proposal to extend eligibility to employees laid off from March 1, 2010 through Dec. 31, 2010. The subsidy period in this legislation is reduced to 12 months.

2)      The pending jobs bill proposes extending eligibility until May 31, 2010. The duration of the subsidy would remain at the current 15 months.

12 months? 15 months? The good news will be extending the benefit for the those in need, but we feel the pain of those once again trying to be ahead of the compliance curve.

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DOL’s New Model Notices Account for COBRA Subsidy Extensions

The American Recovery and Reinvestment Act of 2009 (ARRA) requires that plans notify certain current and former participants and beneficiaries about the changes to premium reduction, enacted in December 2009. The U.S. Department of Labor has now published new model notices for plans / employers to use.

If you use the services of a COBRA administrator, they should take care of the notice requirements on your behalf.

If your plan is subject to State Continuation rather than COBRA, your insurance carrier should be responsible for providing notification to affected members.

You should contact your administrator or carrier, as appropriate, with questions.

For those who self-administer COBRA, however,  you do need to be aware of these notification requirements, and prepare to send out the correct notices within the required timescales.

Going forward, the Updated General Notice should be used for all new COBRA notification events.

You will find the notices, along with more complete information on the updated requirements, at http://www.dol.gov/ebsa/COBRAmodelnotice.html.

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