ARRA COBRA Subsidy Extended

On Saturday, December 19, 2009, the President signed HR 3326 (the Department of Defense Appropriations Act of 2010, DoDAA), which extends the ARRA subsidy. This information became public knowledge on Monday, December 21, 2009. Under HR 3326, major changes to ARRA include:

• Currently, ARRA eligibility for involuntary terminations of employment ends on December 31, 2009. This is now extended to February 28, 2010, without regard to when the COBRA coverage period actually begins.
• The maximum ARRA subsidy period, previously nine months, is now 15 months for all assistance eligible individuals (AEIs). This includes any AEIs whose subsidy expired November 30, 2009.
• Those whose ARRA subsidy ended on November 30, 2009, have an extended grace period in which to pay their COBRA premium. The grace period is now extended until 60 days after the date that the DoDAA was enacted (i.e., February 17, 2010) or, if later, 30 days after a DoDAA notice is sent to them.
• Two new notifications are required. First, plans need to notify all individuals who were AEIs as of October 31, 2009, or la ter of the DoDAA changes. This notice needs to be sent within 60 days of DoDAA's enactment date. A second notice needs to be sent to those AEIs who lost their ARRA subsidy to notify them of their extended payment grace period.

Other bill-related information is available at The Library of Congress website.

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