The IRS has posted its fourth installment of Q & A’s concerning the ARRA COBRA Subsidy.
See also these links from the Department of Health and Human Services (“HHS”):
HHS’s webpage on the COBRA Subsidy here. Helpful Information About State Continuation Coverage (Mini-COBRA Programs) and the American Recovery and Reinvestment Act of 2009 (ARRA) COBRA Helpful Tips
The DOL has posted a draft of the new Application which it will use to review private employer group health plan denials of the COBRA subsidy. The applications have apparently been submitted to the federal Office of Management and Budget for approval by May 15, 2009. In this DOL Supporting Statement here, the DOL provides this estimate of how many applications the agency expects to receive:
The Department estimates that approximately 40.8 million individuals will initially file for Unemployment Insurance between September 1, 2008 and December 31, 2009 from the private-sector. Of these, 11.4 million will be eligible for a COBRA subsidy due to the following factors: their enrollment in employer sponsored insurance (ESI); their employment by a firm of 20 or more employees; and their lack of other options for health insurance coverage. Of those, 50 percent or 5.7 million are expected to actually apply for the subsidy and enroll in COBRA. National Unemployment Insurance data reported a 5.8 percent appeal rate of initial claims in 2008. The Department assumed that roughly half that share, or 3 percent, of those that applied for the subsidy would contact the Department to appeal a denial, or 172,000. Of these, it was assumed that 45 percent, or 77,000, would involve an initial call to an EBSA benefits advisor who would be able to resolve the issue without going through a formal appeal. The remaining 55 percent, or 95,000, would go through a formal appeal.
The Supporting Statement also indicates:
The information provided on the Application will be used by EBSA to make a determination regarding the applicant