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Clarifications Needed Under New COBRA Subsidy Extension
Miller Johnson 
[Guidance Overview] Mar. 5, 2010
Excerpt: * Does the Act require retroactive application where the involuntary termination of employment occurred before March 2, 2010? (It appears that it does not.) * For qualified beneficiaries who elected COBRA on account of the reduction in hours is retroactive application of the subsidy required? (It appears that it is not.) * If a qualified beneficiary wants to retroactively elect and pay for COBRA coverage between the date of the reduction in hours and the involuntary termination of employment, is the group health plan required to allow him/her to do so? (It appears that is not required.)
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