COBRA Subsidy: Part-time to terminated

[Guest shaul]

If a participant becomes eligible for COBRA as a result of a reduction in hours (he is reduced to part-time status) does his subsequent involuntary discharge trigger subsidy rights with respect to the remaining 9 (or fewer) months of COBRA coverage, counted from the date of his involuntary termination? I would assume so, but couldn't find anything explicitly on point.

Thanks very much.

[Guest Sieve]

Depends. The issue is addressed in Rev. Notice 2009-27, Q&A-15.

In short, the answer is that the reduction in hours is the qualifying event, and a subsequent involuntary termination of employment generally will NOT cause the individual to be eligible for the subsidy (unless the reduction in hours is in anticipation of the involuntary termination of employment).

If (under the facts & circumstances) there is eligibility for the subsidy, then that eligibility is of normal length.