The Department of Labor’s Employee Benefits Security Administration (EBSA) updated its web page to clarify the end of the COBRA ARRA subsidy.
FAQ Q1 states that some individuals are eligible to receive the COBRA premium reduction subsidy beyond Aug. 31, 2011. Individuals who qualified on or before May 31, 2010 may continue to pay reduced premiums for up to 15 months, as long as they are not eligible for another group health plan or Medicare even if their COBRA coverage did not start until a later date due to the terms of a severance arrangement, or the use of banked hours or other similar provision that delayed the start of their COBRA coverage.