As December 2009 comes to an end, we want to clarify the subsidy eligibility of an individual with event and loss of coverage dates occurring in December. The ARRA statute defines an Assistance Eligible Individual (AEI) as “any qualified beneficiary if – at any time during the period that begins with September 1, 2008, and ends with December 31, 2009 – such qualified beneficiary is eligible for COBRA continuation coverage."

WHAT THIS MEANS TO YOU AS AN EMPLOYER?
We have usually referred to qualifying events that occur up until December 31, 2009, but that is only part of it. Please also keep the definition of an AEI in mind. For example, if the loss of coverage is December 31, 2009, and COBRA coverage begins on January 1, 2010, the qualified beneficiary will not be eligible for the subsidy in 2010. Please see examples below:

WHAT SHOULD I DO NEXT?
It’s not clear that the subsidy will be extended into 2010. You are probably aware that several bills are currently pending in Congress to extend the ARRA program. If enacted, these laws may be applied retroactively. Until such legislation is passed, the above is the rule for COBRA and ARRA administration. If you have questions about this notice please feel free to reach out to your Corporate Synergies team for assistance.

If you have any additional questions regarding the information within this eCommunication, please call Corporate Synergies at 1.866.CSG.1719 or CLICK HERE to contact us today.

Corporate Synergies is pleased to provide regular updates on issues affecting group benefits insurance. As an insurance broker and consultant, Corporate Synergies monitors federal and state legislative and regulatory activity to ensure that you stay informed.