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Employee Benefits Client Alert
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John McMorrow
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April 20, 2010
New Law Extends COBRA Premium Subsidy Eligibility Period for Two Months
The Continuing Extension Act of 2010 (the Act) was signed into law on April 15, 2010.  The Act extends the COBRA premium subsidy program for two months, through May 31, 2010.  Key provisions of the Act are summarized below.
  1. Extended Expiration Date.  The COBRA subsidy program will be available for a loss of group health coverage due to involuntary termination (or a reduction of hours that is followed by an involuntary termination) through May 31, 2010.
  1. Transition Period. For individuals who experienced a termination of employment on or after April 1, 2010, but before April 16, 2010, the Act requires the Plan Administrator to notify such individuals by June 15, 2010 of their ARRA rights (including the COBRA subsidy) and to allow them to elect COBRA coverage up to 60 days after they are provided with such notification.
In light of the new Act, employers must update their COBRA procedures and forms.
This client alert is intended to inform you of developments in the law and to provide information of general interest.   It is not intended to constitute legal advice regarding a client's specific legal problems and should not be relied upon as such.  This client alert may be considered advertising under the rules of the Massachusetts Supreme Judicial Court.