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This newsletter is brought to you courtesy of The Partners Group and member company, Kerr-Cruickshank, Inc. We are a multi-specialty insurance and consulting firm
that offers creative employee benefits solutions to our customers. As a valued client or associate, we feel this weekly update provides valuable information to you.
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IRS PUBLISHES COBRA SUBSIDY GUIDANCE
Attachment:
IRS Notice 2009-27: Premium Assistance for COBRA Benefits
The Treasury Department has released in the attached notice the greatly anticipated guidance regarding the COBRA Subsidy provisions. These are the provisions that are included in the American Recovery and Reinvestment Act of 2009 (ARRA).
In question and answer format, Notice 2009-27 provides many examples on issues such as:
- events that qualify as involuntary terminations of employment
- definition of an assistance eligible individual;
- calculation of the premium reduction;
- type of benefit coverage eligible for the premium reduction
- the premium reduction period;
- recapture of the premium assistance subsidy; and
- the extended "2nd chance" election period.
This Alert also focuses on a few of the important issues addressed in the notice in regards to Involuntary Terminations. When the original regulations were released, many questions surrounded the definition of what constitutes an
"involuntary termination." Notice 2009-27 provides the details of what circumstances would qualify as an involuntary termination under the ARRA in the first questions and answers section.
It is also important to note that in addition to all the questions surrounding "involuntary termination," the IRS guidance addresses many of the questions we have received from our clients. The attached notice also provides the IRS
response to a few of the more commonly asked questions.
We appreciate your questions and want to continue to be a resource for you as this continues to evolve. In addition, the IRS indicates that it continues to review additional issues relating to the premium reduction provision that are not
addressed within this initial notice and additional guidance may be forthcoming.
As more information becomes available, The Partners Group will continue to provide updates. In the interim, please contact us with any questions you may have. |
