The recently passed Continuing Extension Act of 2010 has extended the 15-month, 65% COBRA subsidy, originally provided by the American Recovery and Reinvestment Act of 2009. Under this extension, an individual may qualify for the subsidy if he or she experiences a COBRA qualifying event, which is the involuntary termination of a covered employee’s employment, at any time from September 1, 2008 through May 31, 2010. For this purpose, an involuntary termination of employment which occurs on or after March 2, 2010 but by May 31, 2010, and which follows a qualifying event that was a reduction of hours occurring at any time from September 1, 2008 through May 31, 2010, is also a qualifying event for purposes of an individual being eligible for the COBRA subsidy.
To help with the administration of the COBRA subsidy, the Employee Benefits Security Administration (the “EBSA”) COBRA page now has available updated Model Notices, Application for Expedited Review of Denial of COBRA Premium Reduction, Fact Sheet, and Frequently Asked Questions (FAQs) that reflect the provisions of the Continuing Extension Act of 2010. The EBSA’s COBRA page is here.