Update on COBRA Premium Subsidy

During the latter part of last week, both the Federal Government and the Ohio General Assembly took actions that affect the COBRA Premium Subsidy authorized by The American Recovery and Reinvestment Act of 2009 [ARRA]. 

• The Internal Revenue Service [IRS] issued a 27 page guidance notice that addresses many issues raised about the Premium Subsidy program.

• The Ohio General Assembly inserted an emergency amendment into the state's transportation-stimulus bill that extends the state's small group mini-COBRA coverage from 6 to 12 months.  It was immediately signed by Governor Strickland.

Please note: Insurance carriers have the responsibility of administering all aspects of the mini-COBRA Premium Subsidy, including providing notices to those potentially eligible for the Subsidy.

To provide you with accurate, useable information about these changes, HORAN is preparing two updates for you:

1. An Alert on new information about the Premium Subsidy that describes the most critical items from the new IRS's notice.  This document will be sent to you via email by Thursday, April 9.

2. The Third Edition of the HORAN Compliance Alert on the Premium Subsidy.  This Alert will provide detailed information regarding how the Premium Subsidy applies to employer group coverage, as well as incorporate the new information from the IRS and the changes to the Ohio mini-COBRA coverage. It will be available as part of the HORAN Compliance Information CD.  (This CD will also provide HORAN compliance briefs on employer responsibilities relating to key laws including:  HIPAA, COBRA, Medicare, Medicare Part D [with mail merge forms], CHIPRA, Summary Plan Descriptions [with mail merge model document] and other information that can assist you with your compliance efforts.)

The Third Edition of the HORAN Compliance Alert on the Premium Subsidy should be used in conjunction with the COBRA Premium Subsidy CD.  This CD is available now, and contains mail merge model notices used to assist you in notifying any former employers who might be eligible.  Please contact your HORAN Account Manager for information regarding the COBRA Premium Subsidy CD.

If you have any questions or concerns regarding this Update, please do not hesitate to contact your HORAN Account Manager.