American Recovery & Reinvestment Act of 2009

On Tuesday, March 31, 2009, the IRS issued its Notice 2009-27 providing additional guidance under the American Recovery & Reinvestment Act of 2009 (“ARRA”) relating to premium subsidies for COBRA coverage. The Notice addresses a number of issues, including the question of who is eligible for the subsidy, the method for calculating the premium reduction, and the length of the entitlement to the subsidy.
Continue Reading IRS COBRA Guidance: What is an “Involuntary Termination?” Potential Disputes Lurk in Definitions