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AZ USA:  Wendsday, December 30 - 2009

Department of Defense Appropriations Act of 2010 Extends COBRA Subsidies

On December 19, 2009, the president signed another bill called the Fiscal Year 2010 Defense Appropriations Act (DOD) which included provisions to amend ARRA. The 2010 DOD Act extends the eligibility period for premium reductions for an additional two (2) months (through February 28, 2010) as well as extending the maximum period to receive government subsidies from 9 to 15 months.

Changes made by the 2010 DOD Act are as follows:

  • The Act changes the end date to whom should be offered COBRA premium subsides from 12/31/2009 to 02/28/2009.
  • The Act extends the maximum period to receive COBRA subsidies from 9 to 15 months.
  • COBRA participants that may have reached the end of their reduced premiums and have terminated from COBRA will be permitted to re-enroll on the plan retroactively. The participant will have until 02/17/2009 or 30-days from the date of the letter (if the 30-day grace period extends past 02/17/2009) to make up premium payments.
  • COBRA participants that have exhausted their subsidy time frame and who has made full premium payments will be notified of the subsidy extension and allowed to choose whether they want a refund of the overpaid premium or if they would like the overpayment credited to future months.
  • Anyone who was an AEI on or after 10/31/2009 must receive a notice explaining the changes made by the 2010 DOD Act.
  • COBRA Qualifiers who were terminated on or after 10/31/2009 must receive a notice explaining the changes made by the 2010 DOD Act.
  • The act also clarifies that the date of the qualifying event should be used in determining an individual’s eligibility for premium assistance and not the date of the qualifier’s COBRA eligibility. Meaning, if an individual experiences a loss of coverage on 02/28/2010, that they may still be eligibility for premium assistance.

COBRA Solutions is currently in the process of updating the COBRA Administration Manager software and expects the new version to be released in the first week of January 2010. Current customers of COBRA Solutions should expect to receive instruction on updating their software and also detailed information on the software changes.

 

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