As we told you in an earlier Employment Law Alert (click here; see news item dated February 27, 2009), the American Recovery and Reinvestment Act of 2009 (ARRA), signed into law last month, makes significant revisions to the health insurance continuation provisions of the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), including a 65% subsidy of COBRA premiums for employees involuntarily terminated from employment between September 1, 2008, and December 31, 2009. This means that for up to nine months, eligible individuals pay only 35% of the premium, while employers cover the remaining 65%. ARRA mandates immediate compliance, which, among other things, requires notifying certain current and former plan participants and beneficiaries about the premium reduction.
On March 19, 2009, the United States Department of Labor issued four “model” notices to assist in compliance with the ARRA’s COBRA requirements. We are providing the web link to each of these model notices. The notices are in Microsoft Word format, so they may be modified, as appropriate, by plan administrators.
Click here for more information, links to the new model notices, and an employer to-do list.