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  COBRA Subsidy Extension Model Forms Published.Barker Olmsted & Barnier - February 05, 2010 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.
Report Link Model COBRA Notice and Guidance Issued for Subsidy Extension.Fredrikson & Byron, P.A. - January 28, 2010 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. Report Link LABOR DEPARTMENT ISSUES MODEL COBRA SUBSIDY EXTENSION NOTICES.Ballard Rosenberg Golper & Savitt - January 28, 2010 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. Report Link COBRA Subsidy Extended; Department of Labor Issues Revised Model Notices.Jones Walker - January 21, 2010 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). Report Link ARRA COBRA Subsidy Extension - Updated Model Notices Published.Vedder Price - January 18, 2010 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. Report Link Publishes Model COBRA Notices, Other Compliance Resources.Ford & Harrison LLP - January 15, 2010 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. Report Link Model COBRA Notices Published - Immediate Attention Required.Vedder Price - April 06, 2009 Model COBRA Notices Published - Immediate Attention Required. Report Link New COBRA Guidance (and Model Notices) from the DOL.Ogletree Deakins - March 31, 2009 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). Report Link COBRA Premium Subsidies Notice Requirements and Action Plan.Jackson Lewis LLP - March 30, 2009 The new American Recovery and Reinvestment Act of 2009 (“ARRA”) provides reductions in premiums and additional opportunities to elect continued group health coverage under COBRA for employees who became eligible for COBRA coverage as a result of an involuntary termination of employment between September 1, 2008, and December 31, 2009. The premium reduction and additional election opportunity also apply to members of the employee’s family who were covered under the group health plan at the time of the employee’s involuntary termination. Employees and family members who are eligible for the COBRA premium reduction are “assistance eligible individuals” under the ARRA. Report Link Model COBRA Notices Published - Immediate Attention Required.Vedder Price - March 25, 2009 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. Report Link Department of Labor Issues New Model COBRA Notices.Baker Hostetler LLP - March 23, 2009 On February 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act of 2009 (the "Act"). The Act provides a subsidy for COBRA premiums for assistance eligible individuals for up to nine months and imposes additional notice requirements. These changes are effective immediately. Baker Hostetler previously distributed an alert entitled COBRA Change Under the American Recovery and Reinvestment Act of 2009 to highlight these changes. On Thursday, February 19, the U.S. Department of Labor published new model COBRA notices to make it easier for employers and administrators to comply with the new COBRA provisions. In addition, the Department of Labor has issued guidance to help employers better understand their new COBRA (and COBRA-related) rights and obligations. Report Link U.S. Department Of Labor Issues New Model COBRA Notices and Additional Guidance.Constangy, Brooks & Smith, LLP - March 23, 2009 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. Report Link Stimulus Package Affects COBRA Notices.Fisher & Phillips, LLP - March 20, 2009 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. Report Link DOL Issues Model Notices for "Second Chance" COBRA Election and Subsidy.Jones Walker - March 20, 2009 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. Report Link DOL Issues Model COBRA Subsidy Notices and Forms.Jackson Lewis LLP - March 20, 2009 The United States Department of Labor (“DOL”) today posted on its website model notices and application forms to be used by employer-sponsored health plans and individuals electing COBRA in connection with the American Recovery and Reinvestment Act of 2009 (“ARRA”) COBRA premium subsidy. The ARRA requires that group health plans notify certain current and former plan participants about the COBRA premium subsidy. Report Link Legal Alert: COBRA Model Notices Issued.Ford & Harrison LLP - March 19, 2009 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. Report Link Department of Labor Issues Final COBRA Notice Regulations.Jackson Lewis LLP - July 14, 2004 On May 26, 2004, the DOL issued final regulations regarding the timing and content requirements of various notices that must be furnished by employers, plan administrators, workers and their families in connection with group health continuation coverage - commonly referred to as COBRA coverage. Report Link Final COBRA Regulations Require Employer Action (pdf).Vedder Price - July 12, 2004 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"). Report Link New COBRA Guidance Requires Employers To Overhaul Notices And COBRA Procedures.Littler Mendelson, P.C. - June 24, 2004 Just over one year ago, the Department of Labor issued proposed COBRA regulations that contained dramatic changes to the content of COBRA notices as well as the manner in which notices were required to be issued. Report Link DOL Issues Final COBRA Notice Regulations.Jackson Lewis LLP - May 28, 2004 On May 26, 2004, the Labor Department issued final rules governing COBRA notice requirements. Generally, the final rules set new minimum standards for the timing and content requirements for providing notice of COBRA group health plan continuation coverage rights to participants and beneficiaries. Report Link DOL Delays Effective Date for Proposed COBRA Notice Regulations.Jackson Lewis LLP - December 18, 2003 The Department of Labor’s Employee Benefits Security Administration has said proposed regulations governing the standards for issuing COBRA notices will give employers at least six months to implement administrative changes required by the new rules after those regulations are finally adopted. Report Link New COBRA Regulations and Sample Notices [PDF File, p.9].Jones Walker - July 24, 2003 On May 28, 2003, the DOL issued proposed regulations that address the timing and content of COBRA notices for employees, employers, and plan administrators. Report Link Eighth Circuit Rules Oral Notice Sufficient for COBRA.Ballard Rosenberg Golper & Savitt - December 02, 2002 COBRA requires written notice when a group plan commences but not when qualifying event occurs, when oral notice is sufficient.
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