The Employee Benefits and Executive Compensation group at Bingham McCutchen LLP put together a nice summary of the steps employers need to take in light of the changes to COBRA under the the American Recovery and Reinvestment Act of 2009. They dive into many of the details of who is eligible for the subsidy and how the reimbursement process works.
See my previous posts:
- COBRA Expansion and Premium Subsidy Under The 2009 Stimulus Act
- Model COBRA Subsidy Notices Released
- More Guidance on Extended COBRA Coverage under ARRA
- COBRA Coverage Under ARRA
In the interest of full disclosure, I am related to one of the authors of the Bingham legal alert.
This is not a reply, but a Question: Do the model notices under the DOL for Cobra require any modification for California employers?
Thanks.
Barbara –
It is my understanding that COBRA is nationwide, but not applicable to all companies. Some states have filled in that gap with mini-COBRAs that follow the federal statute but address a broader range of companies.
But don’t take my word for it! Please consult with a lawyer or your provider.