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Dust Off Your Pre-ARRA COBRA Notices: Eligibility for COBRA Premium Subsidy Expired After May 31, 2010

    Client Alerts
  • June 11, 2010

The latest extension of the COBRA premium subsidy (the "Subsidy") expired on May 31, 2010, and Congress has not extended Subsidy eligibility beyond that date as of this time. In other words, individuals who experience an involuntary termination of employment on or after June 1, 2010 and lose group health plan coverage are not eligible for the Subsidy. 

Therefore, unless and until eligibility for the Subsidy is extended through legislation, individuals experiencing a COBRA-qualifying event on or after June 1, 2010 should receive the same version of the qualifying event notice sent by the plan administrator prior to the enactment of the Subsidy on February 17, 2009. For example, if an employer terminates an employee on June 10, 2010, and as a result of such termination the employee loses health coverage, the plan administrator should provide the individual with the qualifying event notice that does not include information about ARRA or the Subsidy.