Last week, the President signed into law House Resolution 4851, which extends several government programs through May 31, 2010, including the ARRA COBRA subsidy. House Resolution 4851 is referred to as the Continuing Extension Act of 2010. It simply extends the previous COBRA subsidy cut-off date of March 31, 2010 to May 31, 2010. The text of the law briefly explains that those terminated between April 1 and 15 will be retroactively covered by the law similar to past extensions of the COBRA subsidy.
Keep in mind that, as stated in my earlier posts on this subsidy, assistance eligible individuals who are involuntarily terminated are eligible to pay only 35% of their ordinary COBRA premiums for up to 15 months. This applies to individuals involuntarily terminated between September 1, 2008 and May 31, 2010. In addition, as a result of the last extension of the COBRA subsidy, an involuntary termination of employment that occurs on or after March 2, 2010 but before May 31, 2010 and follows a COBRA qualifying event that was a reduction of hours that occurred at any time from September 1, 2008 through May 31, 2010 is also a qualifying event for purposes of ARRA.
The model notices have not yet been updated to reflect this change in date, but the notices, procedures, and timeframes for issuing them will likely be identical to that of the last extension, as this extension makes no substantive changes to the law other than the substituted date.