Like a long-running Broadway show that has come to an end, the curtain has finally dropped on the COBRA subsidy extensions. Three times it was extended, but another extension is not likely to occur, according to our partners at Barran Liebman. This means that employees terminated after May 31, 2010 will not be eligible for the COBRA subsidy.
So what’s the next step? Identify who is eligible for the subsidy. If employees were involuntarily terminated before September 9, 2009 or after May 31, 2010, they are NOT eligible for the subsidy. Those who fall within that time period should continue to receive the subsidy – which lasts for 15 months starting the day they were terminated. You may find some ex-employees’ 15 months have expired. Be prepared to respond to questions they may have.