COBRA Provisions of the American Recovery and Reinvestment Act of 2009

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The recently enacted American Recovery and Reinvestment Act of 2009 (the “Act”) includes several new requirements that will impact the COBRA responsibilities of employers maintaining group health plans. In broad terms, the Act’s COBRA-related provisions do two things, both related to individuals involuntarily terminated between September 1, 2008 and December 31, 2009: (1) provide for a subsidy of COBRA premiums for a nine-month period and (2) require certain additional notifications relating to the COBRA subsidy.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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