The Internal Revenue Service (“IRS”) and Department of Labor (“DOL”) have posted limited initial guidance about temporary requirements added to the group health plan medical coverage continuation requirements of the Consolidated Omnibus Budget Reconciliation Act of 1985, as amended (“COBRA”) by the American Recovery and Reinvestment Act of 2009 (“Stimulus Bill”). The IRS guidance provides preliminary information about what employers must do to claim the COBRA premium subsidy payroll tax credit to help offset the cost of providing required COBRA premium discounts for certain involuntarily terminated former employees and their dependents. Most employers were required to begin granting these COBRA premium discounts beginning March 1. Employers must amend their plans to comply with these mandates and, if they wish to seek reimbursement for COBRA Subsidies, must comply with IRS requirements. Meanwhile, group health plan administrators and insurers must take immediate action to provide required notifications and implement other administrative changes necessary to comply with the new rules.
You can learn more about the Stimulus Bill COBRA Amendments and other changes to group health plan requirements by participating in the March 11, 2009 Health Plan Update Teleconference. Register and get other updates at CynthiaStamer.com.
