On December 19, 2009, President Obama signed the extension of the American Recovery and Reinvestment Act of 2009 (ARRA) COBRA Premium Subsidy into law under the Department of Defense Appropriations Act for Fiscal Year 2010 (DOD). For more information, click here. On January 11, 2010, the U.S. Department of Labor (DOL) issued model notices to help plans comply with their notice obligations under the extension of the COBRA Premium Subsidy.
Each DOL model is designed for a particular group of assistance eligible individuals. The Updated General Notice is for all qualified beneficiaries (not just covered employees) who experienced a qualifying event at any time from September 1, 2008, through February 28, 2010, regardless of the type of qualifying event, and who have not yet been provided a COBRA election notice. The Premium Assistance Extension Notice is for certain individuals who have already been provided with a COBRA election notice that did not include information regarding the changes made to the premium reduction provisions of ARRA by the DOD. The Updated Alternative Notice is for individuals who became eligible for continuation coverage under a state law.