“ARRA Changes Health Care Continuation Coverage under COBRA”

On February 17, 2009, the President signed the American Recovery and Reinvestment Act of 2009 (“ARRA”).  Among other things, ARRA makes a number of changes to health care continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”).  On March 19, 2009 the Department of Labor published model notices that take into account these changes and provide a safe harbor for plans and employees.  This Stroock Special Bulletin provides an overview of some of the key changes to COBRA, their implications for employers and the steps they need to take now.