On December 19, 2009, President Obama signed the Department of Defense Appropriations Act (H. R. 3326, also called the “DOD Act”), which included provisions to extend the COBRA premium assistance established in the American Recovery and Reinvestment Act of 2009 (ARRA).
Extension of Premium Subsidy
The maximum period for receiving ARRA COBRA premium assistance has been extended from 9 months to 15 months. This extension applies to Assistance Eligible Individuals (AEIs) covered before and after the DOD Act. Coverage must be continuous during this time. CONEXIS has already updated its system to allow for automatic extension of billing to COBRA participants at the 35% rate for 15 months. AEIs whose 9-month subsidy expired, but who continued COBRA at the higher rate, will be provided with a credit on their account.
Extension of Eligibility Period
The eligibility period cut off has been extended from December 31, 2009, to February 28, 2010. In addition to extending the date, the DOD Act also “uncoupled” the requirement that the termination and the COBRA-begin date occur within the eligibility period. Going forward, the only requirement to become an AEI is that the involuntary termination occurs between September 1, 2008, and February 28, 2010. When COBRA begins is no longer relevant.
Notification Requirements
Notification of the ARRA COBRA extension changes made by the DOD Act must be provided by February 17, 2010. Notices are required for any individuals who experienced a qualifying event (including voluntary and involuntary termination) on or after October 31, 2009, or who exhausted the original 9-month subsidy and subsequently dropped COBRA. More details on these notices will be provided as they become available. CONEXIS has updated the COBRA election notices to include the extension and eligibility requirements.
Transition Period Rules
A special transition period was established for AEIs who completed the full nine months of ARRA subsidy coverage and then dropped their COBRA coverage or paid the full COBRA premium. AEIs who dropped coverage can reenroll by retroactively paying their reduced ARRA COBRA premiums from the date their coverage ended. Premiums are due within 30 days after notice of the extension is provided to them.
The Department of Labor (DOL) and the Department of Health & Human Services (HHS) continue to provide guidance on the provisions of the ARRA COBRA extension. The DOL recently posted answers to frequently asked questions (FAQs) on its web site. A copy of these FAQs can be found in Related Information.
While we will provide more information as it becomes available, please continue to direct former employees to CONEXIS at (877) 722-2667 for information and answers to their COBRA and ARRA COBRA questions.
Campus Human Resources, Benefits Services
Phone: (310) 794-0830 | Fax: (310) 794-0835
