Among employment law professionals and human resource personnel, the last year has been full of changes. Among the more technical changes are thenew COBRA Subsidy provisions that were passed with the stimulus bill earlier this year.
April 18th is a big deadline for some of the implementation of the provisions — providing notices to some former employees about their rights under COBRA and providing some of them with a second opportunity to enroll. (I’ve covered those notices before in an earlier post.)
If you’re looking for something more in-depth, I’ll be giving an audio (i.e. telephone) conference this Friday, April 17th for Business and Labor Reports. You can sign up directly through the BLR website.
Overall, the Act requires employers to provide notice to “assistance eligible individuals” (AEIs) who have lost or will lose their jobs between September 1, 2008, through December 31, 2009, of their the right to pay reduced COBRA premiums of 35 percent for periods of coverage beginning on or after February 17, 2009, with available coverage lasting up to 9 months following the separation of employment.
Here’s a free sneak preview of one suggestion employers need to be considering now: Figure out who has left employment since September 1, 2008 and particularly those who have been involuntarily terminated. That subset may now be eligible for some assistance with COBRA payments and notices will need to be sent to them promptly.
Time is ticking on compliance. Use this week to catch up.
Any suggestions that have made it easy on you that you can share with other employers? Feel free to comment below. (Remember, however, that I cannot respond to questions due to ethics rules.)