New COBRA Mandates for Employers

Complying With the Continuation Coverage Provisions of the Economic Stimulus Plan

Sweeping changes to COBRA provisions effective immediately

Recording of a 90-minute premium CLE webinar with Q&A

Conducted on Wednesday, April 22, 2009

or call 1-800-926-7926
Program Materials

This seminar will examine the new COBRA provisions in the American Recovery and Reinvestment Act of 2009 and recommend steps employers should take immediately to ensure compliance with the new requirements.


In response to the economic crisis, President Obama signed the American Recovery and Reinvestment Act of 2009 into law on Feb. 17, 2009. Also called the economic stimulus plan, the Act provides a temporary subsidy for COBRA continuation health coverage for involuntarily terminated employees.

The administration of the subsidy is expected to be a compliance nightmare for employers, as more former employees elect continuation coverage and employers attempt to locate previously laid off employees who qualify for the subsidy.

The Act goes into effect almost immediately, forcing employers to act quickly to comply with the law’s new requirements. Failure to comply with the Act’s notice requirements will be subject to the existing COBRA penalty provisions under ERISA and the Internal Revenue Code.

Listen as our authoritative panel of employee benefits attorneys examines the COBRA provisions of the economic stimulus plan and recommends steps employers should take now to ensure compliance with the new requirements.



  1. New COBRA subsidy
    1. Eligibility
    2. Duration of subsidy
    3. Option to change coverage
    4. Special 60-day election period
    5. New notice and reporting requirements
    6. Payroll tax credit
  2. Steps employers should take immediately to ensure compliance
    1. Update COBRA communication materials
    2. Identify eligible individuals
    3. Written notice to eligible individuals
    4. Implement administrative procedures for providing subsidy and obtaining payroll tax credit
    5. Review severance policies and agreements that provide COBRA subsidy to determine if special provisions apply
    6. Coordinate with COBRA vendors and insurance carriers


The panel will review these and other key questions:

  • How does the new Act define an "assistance eligible individual"?
  • How does the new law impact individuals who recently declined COBRA coverage prior to the passage of the new law?
  • What changes do employers need to make to their COBRA notice policies and practices?
  • How do employers apply for the payroll tax credit?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Paul M. Hamburger
Paul M. Hamburger

McDermott Will & Emery

He advises employers on all aspects of their employee benefit programs, including matters affecting tax-qualified...  |  Read More

Stacy H. Barrow
Stacy H. Barrow

K&L Gates

He advises corporate, not-for-profit, governmental and individual clients on matters related to executive compensation...  |  Read More

Keith R. McMurdy
Keith R. McMurdy

Fox Rothschild

He focuses primarily on labor and employment issues arising from the design, drafting and administration of employee...  |  Read More

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