Under the guise of stimulus and recovery, the American Recovery and Reinvestment Act of 2009 (ARRA) includes new COBRA provisions to help eligible unemployed individuals elect and pay for continuation coverage. As if COBRA was not complex enough, these new rules add to the minefield employers must navigate. Rather than simply provide a summary of the new law, the Baker & Daniels benefits and executive compensation group believes that sharing answers to our clients' common questions will provide more practical advice.
To that end, this guide provides our thoughts and advice on a variety of questions raised by ARRA, based upon the statutory language and informal comments from the IRS and DOL. We will regularly update this list of questions and answers on our Web site as we receive more questions from our clients and guidance from government agencies, so please use this link to check back often.