On February 17, 2009, President Obama signed the American Economic Recovery and Reinvestment Plan into law which included significant changes to the group health plan coverage continuation provisions of the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), including a COBRA premium subsidy. The original COBRA subsidy applied only to individuals who experienced an involuntary termination of employment during the period from September 1, 2008 through December 31, 2009. This eligibility period was extended multiple times, with the most recent extension terminating on May 31, 2010.
As of the publication of this Bulletin, the COBRA premium subsidy remains expired and there is no known legislation currently pending which would revive the premium subsidy. Employers are advised to use their pre-premium subsidy COBRA forms for addressing individuals who experienced any termination of employment after May 31, 2010.
If you have questions, please contact one of the following attorneys:
|
Gary J. Gunnett
|
412-288-2210
|
|
|
Jessica A. Ellel
|
412-288-2260
|
|