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Benefits Law
Alert April 6, 2009
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IRS ISSUES
ADDITIONAL GUIDANCE REGARDING
COBRA PREMIUM ASSISTANCE
As we
previously reported to you, the American Recovery and Reinvestment
Act of 2009 ("ARRA") includes provisions that provide a
federal subsidy for the payment of COBRA continuation coverage for
certain employees and covered family members.
In response to
the issues that have arisen with respect to COBRA premium assistance
under ARRA, the Internal Revenue Service ("IRS") has issued
Notice 2009-27 which provides additional guidance, in Q&A format,
on the following issues:
· "Involuntary
Termination";
· "Assistance Eligible Individuals";
· Calculating premium reduction amounts;
· Premium reduction periods;
· Recapture of premium assistance;
· Extended Election Periods;
· Payments to insurers under federal COBRA; and
· Comparable state continuation coverage.
IRS Notice
2009-27 can be obtained from the IRS website at http://www.irs.gov/pub/irs-drop/n-09-27.pdf.
If you have any questions about this COBRA article,
please contact the contributors or your Clark Hill Employee Benefits
attorney.
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For further
information about the content of this Benefits Law Alert, please
contact Edward
C. Hammond at 248-988-1821. To find out more about
Clark Hill and our Employee Benefits team, visit clarkhill.com
or call 800.949.3124
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