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Resources: COBRA Provisions Under ARRA

2010-04-16

The COBRA provisions under the American Recovery and Reinvestment Act of 2009 have resulted in many questions from employers. Hewitt's resources can help employers navigate the COBRA premium assistance available to employees.

The American Recovery and Reinvestment Act (ARRA) was signed into law on February 17, 2009 and included provisions that expanded Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage for certain employees. An individual who was involuntarily terminated from employment on or between September 1, 2008 and December 31, 2009 was entitled to premium assistance for COBRA coverage for up to nine months from the individual's former employer if the individual or any other qualified COBRA beneficiary elected COBRA continuation coverage. In the case of group health plans that charge for COBRA on a calendar month basis, this provision was effective for months of coverage beginning on or after March 1, 2009.

The COBRA premium subsidy program has been extended three times:

  • On December 19, 2009, President Obama signed into law a Defense Department appropriations bill that extended the length of the COBRA subsidy period to 15 months and changed the period of eligibility for the subsidy to February 28, 2010, replacing the December 31, 2009 deadline.
  • On March 2, 2010, President Obama signed the "Temporary Extension Act of 2010" into law. The law extended the program through March 31, 2010 and also expanded eligibility to certain individuals who are involuntarily terminated after they experience a qualifying event of reduction in hours.
  • On April 15, 2010, President Obama signed the "Continuing Extension Act of 2010" into law. The law extended the program from March 31, 2010 to May 31, 2010.

Hewitt Resources


The following Hewitt resources examine the COBRA provisions under ARRA in further detail and provide summaries of the latest guidance:

President Obama Signs Bill Extending COBRA Premium Subsidy, Unemployment Insurance, and Medicare Physician Payment Rates Into Law (April 15, 2010)

President Signs Into Law Temporary Extension of COBRA Premium Subsidy, Unemployment Insurance, and Medicare Physician Payment Update (March 3, 2010)

Health Care Reform Advances and President Extends COBRA Subsidy (December 22, 2010)

Hewitt Comments on Expedited Review of COBRA Premium Subsidy Denials (August 13, 2009)

Special Report: The American Recovery and Reinvestment Act of 2009 and Its Impact on Employers (February 2009)

Additional Government Resources


Department of Labor's Employee Benefits Security Administration (EBSA)
EBSA has published a number of COBRA ARRA resources for employers and employees, which can be found on the DOL Web site.

Internal Revenue Service (IRS)
The IRS also has a dedicated Web page announcing the latest information and guidance regarding the COBRA premium assistance.

Centers for Medicare & Medicaid Services (CMS)
CMS has published resources that may be helpful to state and local government employers that maintain group health coverage for their employees, available on the CMS Web site.