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Prepared for TIC by Mike Ewing, J.D.
Director of Research
United Actuarial Services, Inc.
(317) 580-8659
Fax (317) 580-8651
email: mewing@unitedactuarial.com
© United Actuarial Services, Inc. 2010
2010-01
January 12, 2010
DOL Posts Model Notices
Regarding the New COBRA Subsidy Extension
On December 19, 2009, the President signed into law the
Department of Defense
Appropriations Act, 2010 (2010 DOD Act,
also “the new law”)(Pub. L. 111-118),
which extended the availability of the COBRA premium subsidy under the American
Recovery and Reinvestment Act (ARRA) of 2009 (Pub. L. 111-5) See Special
Bulletin 2009-65 for an initial summary of 2010 DOD Act.
This Client Bulletin will address the mandatory Notice requirements under the new
law. In particular, we’ll take a look at two of the three new Model Notices the DOL
posted online at: http://www.reginfo.gov/public/do/PRAViewIC?ref_nbr=200912-
1210-002&icID=188172, the third notice is for insured plans only.
Changes Made By The New COBRA Extension Law
The 2010 DOD Act extended
the COBRA subsidy eligibility period for two months
until February 28, 2010 and increased
the maximum period for receiving the
subsidy for an additional six months (from nine to 15 months).
Individuals who have reached the end of the original subsidy period (nine months)
will have additional time to pay extension-related reduced premiums that were due
prior to Notice of the changes being provided. To continue their coverage they must
pay the 35% of the COBRA premium costs by the later of:
February 17, 2010,
30 days after Notice of the extension is provided by their plan administrator,
or
the end of the otherwise applicable payment grace period.
Individuals who lost their subsidy but would be eligible for the extension and paid
the full 100%
premium for November, December or January should contact their
plan administrator to discuss a credit for future months of coverage or a
reimbursement of the overpayment.
CLIENT BULLETIN