The Continuing Extension Act of 2010, H.R. 4851, has been signed into law.  This law will extend the 15-month, 65% federal premium subsidy to those individuals involuntarily terminated from employment between April 1, 2010 and May 31, 2010.  

The previous ARRA extension, the Temporary Extension Act of 2010, extended the ARRA Subsidy to include involuntary terminations up to March 31, 2010. 

Future ARRA Extensions Likely    It is likely that there will be further extensions of the ARRA subsidy over the next few months.  There is a bill pending in Congress that would extend the ARRA subsidy to the end of 2010.  These proposed extensions would extend the eligibility to newly terminated employees; the proposed legislation does not appear to extend the ARRA subsidy beyond the current 15-month maximum allowed for each individual.

April Qualifying Event Letters Being Resent:    Later this week we will be resending the Qualifying Event letters to those individuals who were terminated from employment in the month of April for whom Qualifying Event letters have already been sent.  Our software people are getting faster at making the necessary changes, which is helpful as this is the 3rd extension of the ARRA Premium Subsidy in less than 5 months. 

The ARRA Subsidy 15-Month Period Will End For Some:    The ARRA Premium Subsidy was effectively implemented as of March 1, 2009 and, as ARRA provides for maximum of 15-months, any "original" March 2009 ARRA premium subsidy recipients will revert back to the unsubsidized rates after May 31, 2010, assuming that the 18-month COBRA term limitation hasn't already ended their COBRA coverage.  

Note for California and New York employers:  If your group health plan policy was issued in either California or New York, the mini-COBRA programs in those states extend the COBRA period beyond the 18-month period offered under Federal COBRA.  Any individuals who enroll or have enrolled in Cal-COBRA and New York's mini-COBRA after their original 18-month COBRA period ends may find that they have some time left on the ARRA premium subsidy.  For example, if your COBRA effective date was November 1, 2008, the COBRA 18-month term will end on April 30th but the ARRA subsidy 15-month period will end May 31st.  This means that the first month of the mini-COBRA period will be eligible for the ARRA subsidized premium rates.

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