Total Articles: 20
DOL ISSUES UPDATED MODEL NOTICES FOR NEW COBRA SUBSIDY EXTENSION.
Earlier this month we advised that President Obama signed a bill extending the COBRA premium subsidy through March 31, 2010 for covered individuals who experience an involuntary termination. March 4 CM. The new extension bill also expands the subsidy benefit to individuals whose COBRA qualifying event was a reduction in hours between September 1, 2008 through March 31 2010 that caused the loss of their health insurance, followed by termination on or after March 2, 2010 through March 31, 2010.
DOL Releases Updated Model COBRA Notice Packages.
The Department of Labor ("DOL") has recently published a series of updated model COBRA notice packages designed to assist employers and group health plans to properly provide notice to employees concerning the availability of the COBRA continuation coverage premium subsidy (now available through March 31, 2010).
Department of Labor Issues Revised Model COBRA Notices.
The Department of Labor (DOL) has issued revised model COBRA notices due to the most recent changes affecting the COBRA subsidy originally enacted by the American Recovery and Reinvestment Act of 2009 (ARRA). The Temporary Extension Act of 2010 (TEA) extended the period during which an individual could qualify for the subsidy through March 31, 2010. Additionally, TEA, unlike ARRA, allows individuals whose first qualifying event was a reduction in hours but were later terminated during the period from March 2, 2010 through March 31, 2010 to qualify for the subsidy.
COBRA Subsidy Extension Model Forms Published.
The government has published updated model forms for the recently extended COBRA subsidy.
Congress passed legislation on December 19th extending the COBRA subsidy eligibility period and coverage period. The extension came as part of the Fiscal Year 2010 Defense Appropriations Act.
Model COBRA Notice and Guidance Issued for Subsidy Extension.
The Department of Labor has issued several documents relating to Congress’ extension of the COBRA sudsidy. Those documents include a summary of COBRA continuation rights, a Fact Sheet about the subsidy as modified by the recent legislation, and a model COBRA Continuation Coverage Election Notice, which includes a discussion of the subsidy extension.
LABOR DEPARTMENT ISSUES MODEL COBRA SUBSIDY EXTENSION NOTICES.
As part of the 2010 Department of Defense appropriations bill, Congress did two things relating to COBRA. First, it extended the initial eligibility period for subsidized federal COBRA benefits to terminations and layoffs through February 28th (the original deadline was December 31st). Second, it extended the subsidy period from 9 months to 15 months.
COBRA Subsidy Extended; Department of Labor Issues Revised Model Notices.
On December 19, 2009, President Obama signed the 2010 Department of Defense Appropriations Act. Included in this
Act was an extension of the length and availability of the 65% premium subsidy provided to COBRA participants under
the 2009 stimulus act (the American Recovery and Reinvestment Act or “ARRA”). (For information regarding the
original COBRA subsidy, please see our previous E*Bulletins from March 2009 and February 2009).
ARRA COBRA Subsidy Extension - Updated Model Notices Published.
The U.S. Department of Labor (DOL) on January 13, 2010 published updated model COBRA notices that address the COBRA subsidy extension provisions of the Department of Defense Appropriations Act, 2010 (DOD Act). These notices will generally need to be provided to affected individuals by February 17, 2010, but certain individuals will need to receive a notice by January 29, 2010. Accordingly, immediate attention is required.
Publishes Model COBRA Notices, Other Compliance Resources.
As we previously published in our December 21, 2009 Legal Alert, on December 19, President Obama signed into law the Department of Defense Appropriations Act of 2010 (the "2010 DOD Act") extending the 65% COBRA subsidy that had been previously enacted under the American Recovery and Reinvestment Act of 2009 (the "ARRA"). Under the ARRA, eligibility for the 9-month subsidy was scheduled to end December 31, 2009. The 2010 DOD Act made several important modifications to the ARRA, including: (1) extending eligibility for the subsidy to individuals who are terminated through February 28, 2010 ("assistance eligible individuals" or "AEI"s); (2) lengthening the maximum duration of the subsidy from 9 to 15 months; and (3) adding new notification requirements. The 2010 DOD Act also clarified that eligibility for the subsidy depends upon termination date – not the date on which the AEI would otherwise be eligible for COBRA coverage.
Model COBRA Notices Published - Immediate Attention Required.
Model COBRA Notices Published - Immediate Attention Required.
New COBRA Guidance (and Model Notices) from the DOL.
Employers scrambling to comply with the COBRA premium assistance and second-chance election provisions of the American Recovery and Reinvestment Act of 2009 (also referred to as the “federal stimulus bill”) have some useful guidance in the form of eagerly-awaited model notices and other informal guidance from the Department of Labor (DOL).
Model COBRA Notices Published - Immediate Attention Required.
On March 19, the U.S. Department of Labor (DOL) published four model COBRA notices relating
to the COBRA subsidy provisions of the American Recovery and Reinvestment Act of 2009
(ARRA). These model notices require immediate attention by employers and their COBRA
administrators, as an important April 18 deadline for distributing the so-called Second Election
Notice now looms.
U.S. Department Of Labor Issues New Model COBRA Notices and Additional Guidance.
The U.S. Department of Labor released yesterday model notices and additional guidance to assist employers in meeting their new COBRA obligations under the American Recovery and Reinvestment Act of 2009 (also known as the “stimulus package”), which became effective February 17, 2009.
Stimulus Package Affects COBRA Notices.
Yesterday, the U.S. Labor Department (DOL) released model notices regarding the new COBRA requirements that were enacted as part of the American Reinvestment and Recovery Act of 2009 (ARRA). The law mandates that plans notify certain current and former participants and beneficiaries about the COBRA premium subsidy and "second chance" COBRA election opportunity by no later than April 18, 2009.
DOL Issues Model Notices for "Second Chance" COBRA Election and Subsidy.
On March 19, 2009, the U.S. Department of Labor (“DOL”) issued several model notices to cover a variety of COBRA
situations impacted by the American Recovery and Reinvestment Act (the recent stimulus law). First and foremost,
employees who were involuntarily terminated on or after September 1, 2008, and who are not currently covered under
COBRA, may have a second chance to elect COBRA. They must be notified of their new COBRA rights and the new
65% COBRA subsidy by April 18, 2009. The DOL has provided a model notice for that purpose. Employers should
provide such notice as soon as possible because former employees have 60 days from the date the notice is provided to
exercise their second chance election rights, and employers will want to start the clock running.
Legal Alert: COBRA Model Notices Issued.
Earlier today, the Department of Labor ("DOL") released model COBRA Notices required under the COBRA provisions of the 2009 American Recovery & Reinvestment Act ("ARRA" or "Act"). We previously posted legal alerts about how the Act impacts COBRA coverage, and the means by which employers, where applicable, may claim the tax credit for COBRA subsidies paid under the Act.
Department of Labor Issues Model Notices for Subsidized COBRA Premiums
President Obama on Feb. 17, 2009, signed into law the American Recovery and Reinvestment Act of 2009 (the “ARRA”). The ARRA expands the rights of terminated employees and their eligible beneficiaries under the Consolidated Omnibus Budget and Reconciliation Act of 1985, as amended (“COBRA”). Specifically, the COBRA provisions of the ARRA provide that 65 percent of an assistance eligible individual’s COBRA premiums will be subsidized by the U.S. government. While the employer or other plan sponsor is initially required to front the cost of the subsidy, the government will reimburse the entity by providing it with a credit against its payroll taxes and/or a refund.
Final COBRA Regulations Require Employer Action (pdf).
The Department of Labor ("DOL") recently released final regulations governing the timing and content of notices required by the Consolidated Omnibus Budget Reconciliation Act of 1985 ("COBRA").
New COBRA Regulations and Sample Notices [PDF File, p.9].
On May 28, 2003, the DOL issued proposed regulations that address the timing and content of COBRA notices for employees, employers, and plan administrators.
Eighth Circuit Rules Oral Notice Sufficient for COBRA.
COBRA requires written notice when a group plan commences but not when qualifying event occurs, when oral notice is sufficient.
