Legal Update: The Department of Defense Appropriations Act: COBRA Subsidy Extension

This memorandum updates our April 2009 memorandum concerning amendments to the federal law that established a health insurance continuation coverage premium subsidy pursuant to COBRA (the Consolidated Omnibus Budget Reconciliation Act of 1985). The American Recovery and Reinvestment Act of 2009 (ARRA) provided certain individuals whose employment was terminated between September 1, 2008 and December 31, 2009 with a health insurance continuation coverage premium subsidy (i.e., 65% of the individual’s COBRA premium) for up to nine months. The recently enacted Department of Defense Appropriations Act of 2010 (“the Act”) extends and expands upon the ARRA premium subsidy, as detailed in the attached memorandum.