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COBRA Model Notices for 2010 Subsidy Extension

Employee Benefits Law Alert J. Paul Jacobson, Robert D. Rothacker, David P. Olson, Amy A. Ciepluch, Sarah M. Linsley, Marla B. Anderson

As described in more detail in our December 2009 Employee Benefits Law Alert, the Department of Defense Appropriations Act of 2010 (the "Act") extended the availability of the COBRA premium subsidy created under the American Recovery and Reinvestment Act. The subsidy is now available for up to 15 months to certain individuals who are involuntarily terminated from employment between September 1, 2008 and February 28, 2010. The Act also mandated that health plans notify certain current and former participants and beneficiaries about the premium reduction. Yesterday, the Department of Labor published model notices that plan administrators can use to meet this obligation. Employers will want to act quickly to distribute these notices - and in any event must do so - no later than February 17, 2010.

If you have questions regarding who should receive the notices, or any other questions regarding the subsidy, please contact Paul Jacobson at (414) 277-5631 / paul.jacobson@quarles.com, Robert Rothacker at (414) 277-5643 / robert.rothacker@quarles.com, David Olson at (414) 277-5671 / david.olson@quarles.com, Amy Ciepluch at (414) 277-5585 / amy.ciepluch@quarles.com, Sarah Linsley at (312) 715-5075 / sarah.linsley@quarles.com, Marla Anderson at (414) 277-5453 / marla.anderson@quarles.com or your Quarles & Brady attorney.