As previously said here, the recently enacted Temporary Extension Act of 2010 (“TEA”) extended the eligibility for the COBRA premium reduction subsidy for one month. Thus, an individual whose COBRA qualifying event is an involuntary termination of employment occurring on or prior to March 31, 2010 (as opposed to February 28, 2010) may qualify for the subsidy. TEA also expanded eligibility for the subsidy to individuals whose COBRA qualifying event is a reduction of hours, occurring at any time from September 1, 2008 through March 31, 2010, which is followed by an involuntary termination of employment occurring on or after March 2, 2010 through March 31, 2010. If a private employer’s health plan determines that an individual is not entitled to a premium reduction subsidy, the individual can request an expedited review of the denial from the the Department of Labor (the “DOL”).
The DOL’s Employee Benefits Security Administration (the “EBSA”) has now posted on the COBRA webpage the following updates to reflect TEA: