COBRA Model Notices Released


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

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