COBRA subsidy eligibility expires June 1, 2010

As of this date, employees who are involuntarily terminated June 1, 2010 or later are not eligible for the 15 month COBRA subsidy. Congress is set to consider another extension (through the end of the year) next week. Employers have two choices:

Wait until Congress makes a decision on whether to extend the subsidy. Employers have 44 days from the date of the qualifying event to send the notice. This will give employers until mid-July to send notices to employees terminated June 1.

Send non-subsidy COBRA notices to terminated employees. If Congress does reinstate the subsidy, you will then need to send a 2nd COBRA notice explaining the availability of the subsidy.