The Internal Revenue Service has issued Notice 2009-27 (the “Notice”), which contains, in question and answer format, new guidance relating to the COBRA subsidy made available under the American Recovery and Reinvestment Act of 2009 (the “Act”). The Act’s key provisions were discussed in more detail in our prior Alerts. Since the passage of the Act, employers, current and former employees, and benefits practitioners have raised many questions as to the interpretation of the Act. The Notice provides answers to many of these questions. The following are some highlights from the Notice, chosen based on the issues that have been raised most frequently by our clients and colleagues.

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