COBRA - American Recovery & Reinvestment Act

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17 February 2009
by New Agency Partners

In an effort to help you better understand the changes to COBRA under the “The American Recovery and Reinvestment Act of 2009 (ARRA), New Agency Partners offers the following summary and key dates.

In addition, detailed information and links to websites are provided to the left and we will continue to add pertinent information as it becomes available.


Summary

  • The COBRA changes affect both the federal COBRA provisions and the Public Health Service Act program that provides similar extension benefits for public programs. In addition, the subsidy provisions apply to state continuation coverage that is comparable to federal COBRA
  • An individual is eligible for the COBRA premium subsidy if he or she is: involuntarily terminated from employment during the period beginning September 1, 2008 through December 31, 2009 and is eligible to elect COBRA during that time.
  • ARRA provides a subsidy of 65% of the COBRA continuation coverage premiums for eligible individuals for a maximum of 9 months, so that an eligible individual will only have to pay 35% of the COBRA premium to obtain coverage.
  • The subsidy is offset by a tax credit against the employer’s wage withholdings and FICA payroll taxes.

Key Dates

  • Date of enactment is February 17, 2009.
  • The date the subsidy is effective is for the first period of coverage on or after February 17, 2009. (example – March 1, 2009 for calendar plans)


Useful Links:


Cobra Changes and the American Recovery and Reinvestment Act (PDF)


Department of Labor Premium Reduction Fact Sheet (PDF)


Click here for information related to American Recovery and Investment Act of 2009


Click here for a copy of the IRS Press Release
 

Click here for a copy of the:
IRS Q & A
IRS Form 941
IRS Form 941 Instructions


Click here to go to the Department of Labor

  • The subsidized period is a maximum of 9 months.
  • The subsidy applies to eligible individuals who had a qualifying event due to involuntary termination on or after September 1, 2008 through December 31, 2009.
  • Model notices and guidance are expected from the Department of Labor by March 19, 2009.

Notices must be sent to individuals within 60 days of enactment.

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