COBRA Subsidy Extension
by Kelly Baier, Attorney
January 2010 -- The Department of Defense Appropriations Act, signed by President Obama on December 19, 2009, extends the period to qualify for the COBRA premium reduction until February 28, 2010, and also extends the maximum period for receiving the reduction to 15 months.
Individuals whose eligibility for premium reduction expired in November or December of 2009 (individuals in a "transition period") must be provided notice by the Plan Administrator of the extension within 60 days of the expiration of the individual's period of premium reduction.
Plan Administrators must also provide, as part of the COBRA election notice materials, a General Notice to all qualified beneficiaries, not just covered employees, who experience a qualifying event at any time from September 1, 2008, through February 28, 2010, regardless of the type of qualifying event.
Individuals who were "assistance eligible individuals" as of October 31, 2009, and individuals who experienced a termination of employment on or after October 31, 2009, and lost health coverage (unless they were already provided a timely, updated General Notice) must be provided notice of the changes made to the premium reduction provisions by February 17, 2010.
If you have questions regarding this extension of the COBRA subsidy, please contact Laura Mueller (319.861.8721), Vernon Squires (319.861.8726), Kelly Baier (319. 861.8723) or Nancy Wood (319.358.5567).