ARRA COBRA and definitions

[Guest PatriciaT]

Different ARRA question: "qualified beneficiary" is defined pursuant to federal COBRA law. "COBRA continuation coverage", however, includes federal _and_ similar state law.

In NH, civil union partners are eligible for state continuation coverage, but obviously not under federal COBRA (as a "spouse").

It looks, then, like an employer subject to the state-level law has to follow ARRA but a civil union partner (or same-sex spouse in some other states) of an employee of that employer cannot benefit from the subsidy (and that employer needs to be careful about filing for the reimbursement of the subsidy). Is that how others read the law? That is inconsistent to me, but I think that is where the wording leads us.