As discussed in a previous Jackson Walker e-Alert, the American Recovery and Reinvestment Act of 2009 (the ARRA), commonly referred to as the economic stimulus package, includes several important provisions that affect COBRA continuation coverage and places new requirements on employers. Among those requirements is the mandate that employers notify certain current and former participants and beneficiaries about the changes to COBRA coverage.
To help employers in that process, the Department of Labor has today issued model notices that employers can use to comply with the notification requirements. To view the model notices, CLICK HERE.
We urge all employers and plan administrators to take immediate action with regard to these notices. The ARRA requires that for any assistance-eligible individual who became entitled to elect COBRA continuation coverage between September 1, 2008, and the date of the ARRA's enactment (February 17, 2009), employers must provide notice by April 18, 2009. Please note that the ARRA requires you to provide these additional notices to all individuals who were (or will be) entitled to elect COBRA continuation coverage (or similar coverage under state law) between September 1, 2008, and December 31, 2009; the ARRA does not appear to limit these additional notices to those employees who were involuntarily terminated.
If you have any questions regarding upcoming changes to COBRA health plan benefits, please contact one of the following attorneys:
Annie LeBlanc at 214.953.6162 or aleblanc@jw.com
Jim Griffin at 214.953.5827 or jgriffin@jw.com
Chuck Campbell at 512.236.2263 or ccampbell@jw.com
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