In previous alerts, we informed you about changes to COBRA affected by the American Recovery and Reinvestment Act of 2009 ("ARRA"). One of these changes is the availability of a federal subsidy toward health care premiums for nine months after certain employees elect continuation coverage.
Until yesterday, Oregon mini-COBRA allowed Oregonians who worked for small employers (less than 20 employees) to continue coverage for only six months. Yesterday, Governor Kulongoski signed a bill that changed Oregon mini-COBRA for employees who have lost or will lose their jobs between September 1, 2008, and December 31, 2009. The bill:
Extends the amount of time from six months to nine months that employees can continue coverage through the state continuation program.
Gives employees who lost their job before February 16, 2009, and who did not then elect continuation coverage a second opportunity to do so.
Requires insurers to notify all employers and former employees about the possibility of the subsidy and the eligibility requirements. Former employees have 31 days from the date they receive notice to elect continuation coverage.
Employees who worked for small employers and who lost their jobs on or after September 1, 2008, should receive a notice in the mail by June 1, 2009 about their eligibility for the subsidy and appropriate instructions.
If you are an employer covered by Oregon mini-COBRA, you should be aware of these changes even though the new legislation imposes the notification requirements on insurers and not employers.