COBRA ARRA Subsidy has been extended from 9 to 15 months!

Individuals currently receiving the COBRA subsidy are entitled to an additional six months of subsidized COBRA premiums, assuming the individuals remain eligible. The measure also provides an additional six months of subsidized COBRA coverage for eligible individuals who exhausted their nine-month COBRA subsidy before December 31, 2009. Such individuals will receive an opportunity to reinstate their coverage and make retroactive premium payments, and continue their subsidized COBRA coverage for an additional six months from the date they originally lost the subsidy.

In addition, the measure allows employees who are involuntarily terminated through February 28, 2010, to take advantage of the COBRA subsidy. This window of opportunity was previously set to close on December 31, 2009.

While the legislation is written in terms of the federal COBRA law, the current premium subsidy applies to both COBRA and state-enforced, "mini-COBRA" laws. Therefore, it is likely that the extension of the eligibility and subsidy will apply to both.

We will keep you updated as more information becomes available.