Changes to COBRA in the ARRA

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COBRA subsidy background and FAQ

The American Recovery and Reinvestment Act (ARRA) created a temporary subsidy for certain individuals with either federal COBRA or state continuation coverage that is comparable to COBRA. While this law took effect February 17, 2009, the Departments of Labor (DOL), Treasury, and Health and Human Services are still working on some implementation rules and details.

The FAQs below reflect the COBRA and state continuation coverage subsidy requirements. The answers may change as the federal agencies issue further guidance. These FAQs provide information only. Kaiser Permanente does not provide legal or tax advice.

For our employer groups that are subject to federal COBRA, but for whom we do not bill and collect federal COBRA premiums directly from members, Kaiser Permanente has very little to do in administering the subsidy. Those groups should continue to send the entire COBRA premium payment to Kaiser Permanente to maintain coverage for their federal COBRA members.

Employer groups that have questions regarding their own responsibilities under this new law, including notification requirements, should contact their legal counsel or the Department of Labor

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