A number of important questions have arisen in light of the COBRA subsidy provisions of ARRA. The Department of Labor has just issued Model Notices that employers can use to comply with certain of their obligations, and we expect the Internal Revenue Service to issue additional guidance on many aspects of the subsidy program, including what constitutes an involuntary termination for purposes of the subsidy.
In this teleconference, we will review the requirements of the subsidy program, provide updates on any additional guidance issued by the Internal Revenue Service and the DOL, and discuss some commonly asked questions about how an employer can administer its COBRA process in light of the availability of the subsidy.
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