Kenneth A. Sprang, EsquireContributing Editor and Consultant HR & Benefits Essentials

Lillian Shapiro, Managing PartnerHR & Benefits Essentials

COBRA SUBSIDYAmerican Recovery and Reinvestment Act of 2009

IntroductionIntroductionIntroductionIntroduction

COBRA Subsidy is part of federal stimulus package known as the American Reinvestment and Recovery Act of 2009 (ARRA)

Signed into law February 17, 2009

Effective for most employers and employees on March 1, 2009

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What Does the New Law Do?What Does the New Law Do?What Does the New Law Do?What Does the New Law Do?

THREE ELEMENTS

1. ARRA provides that the federal government will pay 65% of the COBRA premium for up to 9 months for eligible individuals involuntarily terminated from their employment.

2. Law also extends the period during which COBRA-eligible persons may elect COBRA coverage.

3. Allows employers option to offer alternate coverage

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Who Is Eligible?Who Is Eligible?Who Is Eligible?Who Is Eligible?

The subsidy is available to any “Assistance Eligible Individual” (“Eligible Individual”).

An Eligible Individual is one who:

Is a “qualified beneficiary”

As a result of an involuntary termination of employment between September 1, 2008 and December 31, 2009;

Is eligible for COBRA continuation coverage at any time during that period; and

Elects the COBRA coverage

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What Is Involuntary Termination?What Is Involuntary Termination?What Is Involuntary Termination?What Is Involuntary Termination?

Involuntary termination includes:

Lay-off with or without recall rights and

Other suspension of employment, resulting in a loss of health coverage.

Resignation

As a result of a material change in geographic location of employment; or

Following employer-imposed reduction in hours where reduction in hours is a material negative change in the employment relationship for the employee

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Does not include reduction of hours alone!

What Is Involuntary Termination (cont’d)What Is Involuntary Termination (cont’d)What Is Involuntary Termination (cont’d)What Is Involuntary Termination (cont’d)

Retirement (if employee knows only alternative to retirement is termination).

Termination

While employee is absent because of illness or disability; or

“For cause,” unless the “cause” is gross misconduct. Termination for gross misconduct is not a qualifying event.

Lockout (but not a strike).

Buy-out in return for severance package, if after offer period some employees are to be terminated.

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What Is Gross Misconduct?What Is Gross Misconduct?What Is Gross Misconduct?What Is Gross Misconduct?

Gross misconduct includes

Illegal or dangerous acts committed in the workplace.

Acts that occur away from the workplace may qualify.

Defined by courts as “intentional, wanton, willful, reckless, or deliberate indifference to an employer's interest.”

Generally must more than simple negligence or incompetence.

Examples:

Teacher arrested for sex crimes

Airline attendant strikes a coworker during a flight.

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We recommend consulting employment counsel if you believe you have grounds based upon gross misconduct!

What If The Employee Was Laid Off Prior What If The Employee Was Laid Off Prior to September 1, 2008?to September 1, 2008?What If The Employee Was Laid Off Prior What If The Employee Was Laid Off Prior to September 1, 2008?to September 1, 2008?

Persons involuntarily terminated before September 1, 2008, are not eligible for the subsidy.

Exclusion applies even for those currently using COBRA continuation coverage which began before September 1, 2008

See example

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What If COBRA Benefits Start After September 1, What If COBRA Benefits Start After September 1, Despite Earlier TerminationDespite Earlier TerminationWhat If COBRA Benefits Start After September 1, What If COBRA Benefits Start After September 1, Despite Earlier TerminationDespite Earlier Termination

EXAMPLE

Employee was laid off on June 15, 2008, but received severance pay, including health insurance benefits, through December 31, 2008.

Employee is not eligible for the subsidy in March 2009.

Date of involuntary termination that controls--in this case June 15, 2008.

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Is The Premium Reduction Available After Is The Premium Reduction Available After December 31, 2009?December 31, 2009?Is The Premium Reduction Available After Is The Premium Reduction Available After December 31, 2009?December 31, 2009?

Yes! Premium reduction is available after December 31, 2009, for persons who qualify as Eligible Individuals on or before December 31, 2009.

See example.

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Example-Premium Reduction Example-Premium Reduction After December 31, 2009After December 31, 2009Example-Premium Reduction Example-Premium Reduction After December 31, 2009After December 31, 2009

EXAMPLE

On December 15, 2009, an employee is involuntarily terminated and elects COBRA coverage that day.

She will receive the subsidy for 9 months, until August 15, 2010, or

Until she becomes eligible for other group health plan coverage or Medicare.

What Plans Are Covered?What Plans Are Covered?What Plans Are Covered?What Plans Are Covered?

ARRA provides subsidies for “COBRA continuation coverage,” which is required for “group health plans”

A group health plan generally includes any plan sponsored by an employer or employee organization to provide health care.

Applies to health insurance (including self-insurance) and Health Reimbursement Arrangements (HRA).

Does not apply to Flexible Spending Accounts (FSA) and Cafeteria Plans!

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How Does ARRA Affect State ”Mini-How Does ARRA Affect State ”Mini-COBRA Plans?COBRA Plans?How Does ARRA Affect State ”Mini-How Does ARRA Affect State ”Mini-COBRA Plans?COBRA Plans?

Most states have “Mini-COBRA” plans that cover employers with fewer than 20 employees.

ARRA subsidy applies to State “mini-COBRA” plans if coverage is “comparable” to COBRA.

Comparable continuation coverage does not include every State law right to continue health coverage

To be comparable, Eligible Individual must generally have right to continue coverage substantially similar to that provided under the group health plan at a monthly cost based on a specified percentage of the plan's cost of providing such coverage, i.e., a limit on the premium.

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What If Length of State Coverage or What If Length of State Coverage or Qualifying Events Differ From COBRA?Qualifying Events Differ From COBRA?What If Length of State Coverage or What If Length of State Coverage or Qualifying Events Differ From COBRA?Qualifying Events Differ From COBRA?

A different period of continuation coverage under a State Mini-COBRA program does not disqualify the State program from being comparable.

Variation in qualifying events does not disqualify the State program.

See example.

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Example—State Mini-Cobra Example—State Mini-Cobra VariablesVariablesExample—State Mini-Cobra Example—State Mini-Cobra VariablesVariables

EXAMPLE

State program provides for maximum of 6 months (rather than 18 months under COBRA) continuation coverage (but premiums are the same as those paid for active employees).

States requires that the employee be covered for a period of time, typically 3 months, prior to the qualifying event.

Program is treated as comparable continuation coverage for purposes of the ARRA.

State Programs Qualified for COBRA State Programs Qualified for COBRA SubsidySubsidyState Programs Qualified for COBRA State Programs Qualified for COBRA SubsidySubsidy

The following states have “Mini-COBRA” plans which may be eligible for the ARRA federal subsidy:

AR , CA,CO, CT, FL, GA, IL, IA, KS, KY, LA, ME, MD, MA, MN, MS, MO, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, RI, SC, SD, TN, TX, UT, VA, VT, WV, WI, WY

The following states have no provision for continuation coverage:

AL, AK, AZ, DE, HI, ID, IN, MI, MT, PA (pending legislation), WA.

The following states offer less than nine months continuation:

AR (120 days), NE (6 months), NM (6months), OK (1 month—pending legislation would increase to 4 months), SC (6 months), TN (3 months), VA (90 days).

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Many states modifying their programs in light of the ARRA. Check with State Insurance Commission to confirm your state’s program.

COBRA BeneficiariesCOBRA BeneficiariesCOBRA BeneficiariesCOBRA Beneficiaries

Subsidy also applies to COBRA beneficiaries other than the employee:

Employee’s spouse (as defined under federal law, which excludes same sex spouses)

Employee’s dependent child or other dependent (as defined by the plan and consistent with federal law)

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What About Domestic Partners?What About Domestic Partners?What About Domestic Partners?What About Domestic Partners?

Domestic partners, whether same sex or opposite sex, are not covered because they are not “qualified beneficiaries” under federal law.

Domestic partner who qualifies as a “dependent” under the Internal Revenue Code may qualify. Domestic partners are dependents only if

1. Employee provides over half of the domestic partner’s support; and

2. Domestic partner’s principal abode is with the employee and the partner is with the employer for the entire taxable year.

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How Long Does the Subsidy Last?How Long Does the Subsidy Last?How Long Does the Subsidy Last?How Long Does the Subsidy Last?

Maximum of 9 months.

Subsidy ends earlier if Eligible Individual becomes eligible for other group coverage or Medicare.

Individual may continue COBRA coverage for the maximum period (typically 18 months), even if s/he is eligible for coverage in another group plan or Medicare.

However, the Eligible Individual must then pay 100% of the premium.

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Duration of SubsidyDuration of SubsidyDuration of SubsidyDuration of Subsidy

Premium reduction does not extend beyond the period of person’s COBRA coverage.

Eligible Individuals under State Mini-COBRA plans may be affected.

No impact likely for Eligible Individuals under federal COBRA because the minimum length for COBRA is 18 months. Subsidy is only 9 months.

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Examples—Subsidy Duration Examples—Subsidy Duration IssuesIssuesExamples—Subsidy Duration Examples—Subsidy Duration IssuesIssues

EXAMPLES1.STATE MINI-COBRA. Employee is terminated

December 1, 2008. In a state with only 6 months of continuation benefits, his coverage ends on June 1, even though the subsidy could continue for 9 months, i.e., until December 1, 2009.

2.FEDERAL COBRA. Employee is terminated September 1, 2008. COBRA would end March 1, 2010 (18 months). Subsidy would begin March 1, 2009 and end January 1, 2010.

Mandatory Employee Notice of New Mandatory Employee Notice of New CoverageCoverageMandatory Employee Notice of New Mandatory Employee Notice of New CoverageCoverage

Eligible Individual receiving the subsidy must notify group health plan if he or she becomes eligible for coverage under any other group health plan or Medicare.

Failure to notify the plan will subject the Individual to a tax penalty of 110% of the premium subsidy improperly received after the Individual became eligible for other coverage.

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We strongly recommend that employers require the notice in writing, though they may need to accept oral notice!

Eligibility For Coverage Exceptions Eligibility For Coverage Exceptions Eligibility For Coverage Exceptions Eligibility For Coverage Exceptions

Eligibility for coverage under another group health plan does not terminate eligibility for the premium subsidy if the other plan

Provides only dental, vision, counseling, or referral services (or a combination of these);

Is a health flexible spending arrangement (FSA) or health reimbursement arrangement (HRA); or

Is coverage for treatment furnished in an on-site medical facility maintained by the employer that consists primarily of first-aid services, prevention and wellness care, or similar care (or a combination of such care).

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Extended Election PeriodExtended Election PeriodExtended Election PeriodExtended Election Period

Subsidy must be extended to persons who were

Involuntarily terminated between September 1, 2008 and February 16, 2009;

Have never elected COBRA or

Elected COBRA earlier, but ended coverage before February 17, 2009, e.g., Individual could not afford premiums.

Eligible Individual has 60 days from receipt of Notice to elect.

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Extended Election Period-TermExtended Election Period-TermExtended Election Period-TermExtended Election Period-Term

If election is made within the special election period COBRA will:

Only cover the Individual from his or her election date after March 1, 2009.

Maximum COBRA coverage (18 or 36 months depending on circumstances) will be measured from original qualifying event, not from date of COBRA election.

See example.

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COBRA Duration For Those COBRA Duration For Those Electing During Special PeriodElecting During Special PeriodCOBRA Duration For Those COBRA Duration For Those Electing During Special PeriodElecting During Special Period

EXAMPLE

Employee was involuntarily terminated on September 2, 2008. She could not afford the COBRA premium and did not elect COBRA coverage. Under the ARRA, she elects coverage on March 1, 2009. Her COBRA coverage will end 18 months from September 2, 2008, i.e., March 2, 2010, rather than September 2, 2010.

Does the Special Election Period Apply Does the Special Election Period Apply To State Programs?To State Programs?Does the Special Election Period Apply Does the Special Election Period Apply To State Programs?To State Programs?

No. However, some states are adopting legislation allowing for a special election period.

If a State program provides for a similar special election and an employee otherwise satisfies the requirements to be an a Eligible Individual, he or she is entitled to the subsidy.

The following states have enacted legislation to allow a special election period:

GA, KS, KY, MD, NH, NJ, NY, RI, SD, UT, VA, WV.

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When Is the Special Election Premium When Is the Special Election Premium Due?Due?When Is the Special Election Premium When Is the Special Election Premium Due?Due?

Eligible Individuals who elect COBRA during the Special Election period must pay their first premium no more than 45 days following the date of electing COBRA.

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How Does The Special Election Period Affect How Does The Special Election Period Affect HRA’sHRA’sHow Does The Special Election Period Affect How Does The Special Election Period Affect HRA’sHRA’s

An Eligible Individual who elects COBRA continuation coverage with an HRA during the special election period, will enjoy the same benefits he or she had prior to the date employment terminated.

Amount available through the HRA will be reduced by the total of any reimbursements made after the termination date.

The Individual will not be entitled to reimbursement from the HRA for expenses incurred between November 15, the date of termination, and April 1, the effective date of the new COBRA coverage.

See example

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EXAMPLE

Employee was terminated November 15, 2008. In December he submitted expenses of $500 incurred in October 2008 for reimbursement from the HRA.

The employee enrolls in COBRA now on April 1. The amount available beginning April 1 period will be reduced by the $500 paid in December.

The employee may not be reimbursed for medical expenses incurred between the date of termination on November 15, 2008 and the date of enrollment on April 1, 2009.

Does the Subsidy Program Impact HIPAA? Does the Subsidy Program Impact HIPAA? Does the Subsidy Program Impact HIPAA? Does the Subsidy Program Impact HIPAA?

Under HIPAA, maximum exclusion period for preexisting conditions is 12 months.

Reduced by employee’s prior creditable coverage if break between the previous coverage and new coverage is 63 days or less.

Under ARRA, if an Eligible Individual elects COBRA during the special election period, the period between the loss of coverage and the new coverage is disregarded.

May count creditable coverage preceding the involuntary termination, though the gap between loss of coverage and the new COBRA election is more than 63 days.

HIPAA certificates must reflect this rule.

Example follows31

HIPAA ExampleHIPAA ExampleHIPAA ExampleHIPAA Example

EXAMPLE

Employee was laid off October 7, 2008. She could not afford COBRA premiums so has been uninsured since that date.

Prior to October 7 she had creditable coverage for 12 months. She elects COBRA during the extended election period on March 18, 2009.

She is deemed to have 12 months creditable coverage on March 18, 2009, notwithstanding the gap between October 7 and March 18. She will not have any exclusion for preexisting conditions.

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How Does the Individual Receive the How Does the Individual Receive the Subsidy?Subsidy?How Does the Individual Receive the How Does the Individual Receive the Subsidy?Subsidy?

Eligible Individual who pays 35% of the COBRA premium deemed to have paid in full.

Group health plans must generally treat Individual as having paid the full amount of the premium.

Failure of Plan to treat the premium as paid in full may subject Plan to excise tax.

The employer, plan or insurer must cover the government subsidy until the government reimburses the applicable entity for its share of the COBRA subsidy.

Reimbursement will come through a credit on payroll taxes, including FICA.

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Who Is Entitled Reimbursement?Who Is Entitled Reimbursement?Who Is Entitled Reimbursement?Who Is Entitled Reimbursement?

Reimbursement made to “person to whom premiums are payable” (the “Payee”). Payee determined by nature of the plan.

Multiemployer Plan—Plan gets the tax credit/reimbursement.

Group Health Plan subject to COBRA or plan some or all of which is not provided by insurance—Employer gets the credit/reimbursement.

Fully insured plans subject to State continuation coverage requirements--Insurer gets the credit/reimbursement.

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How Are Employers et al How Are Employers et al Reimbursed?Reimbursed?How Are Employers et al How Are Employers et al Reimbursed?Reimbursed?

Payee is entitled to reimbursement for premiums not paid by Eligible Individuals in the form of

A credit against payroll tax liabilities. For this purpose, payroll taxes are defined as

Federal income tax withholding, the employee share of FICA, and the employer share of FICA tax.

Credit is claimed on the payroll tax return, in most cases Form 941, filed quarterly.

If the credit exceeds payroll tax liabilities on the return, the Premium Recipient is entitled to a refund of such excess as if it were a payment of payroll taxes.

There are no exceptions.

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Example—No Exceptions.Example—No Exceptions.Example—No Exceptions.Example—No Exceptions.

EXAMPLE

In plan under a State Mini-COBRA provision, the employer pays the full premium to the insurer and collects the 35% from the employee. The Employer is not permitted to take the credit.

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Overpayment of PremiumOverpayment of PremiumOverpayment of PremiumOverpayment of Premium

If an Eligible Individual pays 100% of the premium for the first or second coverage period after February 17, 2009, e.g., March and April (perhaps because the employer, plan or insurer was not ready to comply), the Payee must either:

Reimburse the Individual for the amount of premium that exceeds 35% of total premium, OR

Provide a “credit” for such amount that reduces one or more subsequent premium payments (to be used within 180 days)

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Denial of COBRA SubsidyDenial of COBRA SubsidyDenial of COBRA SubsidyDenial of COBRA Subsidy

Persons denied treatment as Eligible Individuals and therefore denied the subsidy have 15 days from the decision to appeal to the

Department of Labor (Most plans)

Health and Human Services (Plans provided outside of ERISA)

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Employer Subsidized Benefits & Employer Subsidized Benefits & COBRA SubsidyCOBRA SubsidyEmployer Subsidized Benefits & Employer Subsidized Benefits & COBRA SubsidyCOBRA Subsidy

Subsidy applies only to that portion of the COBRA premium paid by the employee.

If employer pays part of the premium, the subsidy will only be 65% of the Eligible Employee’s portion of the premium.

Example to follow

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Example--Employer Subsidized Example--Employer Subsidized Benefits Benefits Example--Employer Subsidized Example--Employer Subsidized Benefits Benefits

EXAMPLE

Monthly premium is $1500

Employer voluntarily contributes $500 toward the premium, e.g., as part of a severance package, leaving the employee with a balance of $1,000 per month.

With the subsidy, the employee will pay $350 monthly, (35% x $1,000)

The $650 balance of the employee portion of the premium will be paid by the employer or the insurer and reimbursed by the federal government through a payroll tax credit.

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Taxing of SubsidyTaxing of SubsidyTaxing of SubsidyTaxing of Subsidy

For most Eligible Individuals, the subsidy is tax free

Individuals earning between $125,000 and $145,000 ($250,000 to $290,000 for joint returns) will pay income tax on a portion of the subsidy received. Those earning more than $145,000 ($290,000 for joint returns) will pay tax on the entire subsidy.

Highly compensated Eligible Individuals may avoid the tax on the subsidy benefit by “permanently” waving their rights to the subsidy.

The Eligible Individual must inform the plan of his or her intention to waive.

If the Eligible Individual permanently waives the subsidy it cannot be claimed in subsequent year.

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Employers Offering Optional Employers Offering Optional CoverageCoverageEmployers Offering Optional Employers Offering Optional CoverageCoverage

Employer may allow an Eligible Individual to elect coverage different from that in which he/she was enrolled prior to the involuntary termination

Premium reduction available for this optional coverage.

Employer must also offer the option of enrolling in the coverage the Individual had before the termination.

Individual has 90 days from receipt of notice of the optional coverage to elect it.

This is a change from current COBRA law which allows qualified beneficiaries to elect only the coverage in which they were enrolled prior to the qualifying event.

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Employer Obligations for Alternate Employer Obligations for Alternate CoverageCoverageEmployer Obligations for Alternate Employer Obligations for Alternate CoverageCoverage

If the Employer offers the optional coverage option to Eligible Individuals:

The premium for the optional coverage cannot exceed the premium for the current plan of enrollment;

The optional coverage must also be offered to active employees; and

The alternative coverage cannot be:

Solely dental, vision or EAP

A Flexible spending account

An on-site medical facility

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Time for Election of Alternate Time for Election of Alternate CoverageCoverageTime for Election of Alternate Time for Election of Alternate CoverageCoverage

If employer offers alternative coverage, the employer must allow Eligible Individuals 90 days in which to make the election.

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COBRA Subsidy Notice COBRA Subsidy Notice Requirements: GENERAL NOTICERequirements: GENERAL NOTICECOBRA Subsidy Notice COBRA Subsidy Notice Requirements: GENERAL NOTICERequirements: GENERAL NOTICE

Four different forms of notice

General Notice. Must be sent to all qualified beneficiaries (not just covered employees), who experience qualifying event of any kind at any time from September 1, 2008 through December 31, 2009, and

Have not yet been provided an election notice; or

Who were provided an election notice on or after February 17, 2009 that did not include the additional information required by ARRA.

Distributed within 60 days of qualifying event or February 17, 2009.

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DOL Model Notice: http://www.dol.gov/ebsa/COBRAgeneralnoticefullversion.doc

COBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: ABBREVIATED NOTICEABBREVIATED NOTICECOBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: ABBREVIATED NOTICEABBREVIATED NOTICE

General Notice (Abbreviated version).  Includes same information as the full version regarding the availability of the premium reduction and other rights under ARRA, but does not include the COBRA coverage election information.

May be sent to individuals who

Experienced a qualifying event on or after September 1, 2008

Have already elected COBRA coverage; and

Still have COBRA coverage.

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DOL Model Notice: http://www.dol.gov/ebsa/COBRAgeneralnoticeabbreviatedversion.doc

COBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: ALTERNATIVE NOTICE—State Mini-ALTERNATIVE NOTICE—State Mini-COBRACOBRA

COBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: ALTERNATIVE NOTICE—State Mini-ALTERNATIVE NOTICE—State Mini-COBRACOBRA

Alternative Notice. Insurance issuers that provide group health insurance coverage must send this Notice to persons who became eligible for continuation coverage under a State law.

Issuers should modify this model notice as necessary to conform it to applicable State law.

Issuers may also find the Alternative Notice or the Abbreviated General Notice appropriate for persons who

Experienced a qualifying event on or after September 1, 2008

Have already elected COBRA coverage; and

Still have COBRA coverage.

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DOL Model Notice: http://www.dol.gov/ebsa/COBRAalternativenotice.doc

COBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: EXTENDED EXTENDED ELECTIONELECTION PERIOD PERIOD NOTICENOTICE

COBRA Subsidy Notice Requirements: COBRA Subsidy Notice Requirements: EXTENDED EXTENDED ELECTIONELECTION PERIOD PERIOD NOTICENOTICE

Notice in Connection with Extended Election Period. Plans must send this notice to any Eligible Individual (or any individual who would be eligible if a COBRA continuation election were in effect) who:

Had a qualifying event at any time from September 1, 2008 through February 16, 2009; and

 Either did not elect COBRA continuation coverage, or who elected it but subsequently discontinued COBRA

Notice was to go out 60 days following adoption of ARRA, i.e., April 18, 2009.

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DOL Model Notice: http://www.dol.gov/ebsa/COBRAextendedelectionperiodnotice.doc

Consequences of Late NoticeConsequences of Late NoticeConsequences of Late NoticeConsequences of Late Notice

If notice is late, special election period continues until the Eligible Individual is provided the required notice

Plan Administrator is liable for late notice, as under current COBRA rules.

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Action Plan for ComplianceAction Plan for ComplianceAction Plan for ComplianceAction Plan for Compliance

1. Identify the Eligible Individuals who have not elected COBRA or who elected COBRA and then relinquished it.

2. Determine whether any optional coverage will be offered. If offered, determine the enrollment period for optional coverage.

3. Issue all required notices in a timely fashion.

4. Prepare subsidy waiver form for highly compensated employees, and an “attestation of eligibility” form for all Eligible Individuals.

5. Employer will need to revise HIPAA creditable coverage certificates for those who take advantage of the special election period.

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Action Plan (cont’d)Action Plan (cont’d)Action Plan (cont’d)Action Plan (cont’d)

6. Employer will need to revise HIPAA creditable coverage certificates for those who take advantage of the special election period.

7. Implement a procedure for crediting Eligible Individuals who pay more than 35% of the COBRA premium during first two months of the subsidy period, i.e., after March 1, 2009.

8. Prepare accounting and payroll staff to calculate new premium structure and arrange to obtain tax credit.

9. Review/amend plan documents, SPDs

10. Develop procedure for notifying Eligible Individuals when premium subsidy is about to be exhausted (after 9 months)

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Action Plan (cont’d)Action Plan (cont’d)Action Plan (cont’d)Action Plan (cont’d)

11.  Employers should review severance procedures, if any, and health plan documents to determine the impact of ARRA on these plans.

12. Employer must update COBRA forms and to ensure compliance with the new law.

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Thank You for Joining Us TodayThank You for Joining Us TodayThank You for Joining Us TodayThank You for Joining Us Today

Thanks for joining us today to learn more about…

COBRA SUBSIDYCOBRA SUBSIDYAmerican Recovery and Reinvestment Act of 2009American Recovery and Reinvestment Act of 2009

Presented byPresented by

Kenneth A. Sprang, EsquireKenneth A. Sprang, Esquire

Contributing Editor and Consultant Contributing Editor and Consultant

HR & Benefits EssentialsHR & Benefits Essentials

(202) 895-1504 or (202) 683-4090(202) 895-1504 or (202) 683-4090

ksprang@dcinternationalcounsel.comksprang@dcinternationalcounsel.com

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