Employers, plan administrators and group health plan insurers have more information about what terminations are considered “involuntary” and the meaning of other requirements imposed by temporary modifications (COBRA Subsidy Rules) to the group health plan medical coverage continuation requirements of the Consolidated Omnibus Budget Reconciliation Act of 1985, as amended (COBRA) enacted under the American Recovery and Reinvestment Act of 2009 (Stimulus Bill).The Internal Revenue Service (IRS) yesterday (April 1, 2009) released additional guidance about the COBRA Subsidy Rules, including information about the definition of “involuntary termination.” Part of a series of guidance trickling out from the IRS, the Department of Labor (DOL) and the Department of Health & Human Services (HHS) about the COBRA Subsidy Rules. The IRS publication of this guidance follows the release by March 20, 2009 of its Model Notices notify certain current and former participants and beneficiaries about some of the Stimulus COBRA Rules.
