On February 17, 2009, President Obama signed into law the American Recovery and Reinvestment Act of 2009 (“ARRA”), also known as the Federal Stimulus package. One of the provisions in the ARRA amends the Consolidated Omnibus Budget and Reconciliation Act (“COBRA”) to provide a partial subsidy of the COBRA premium for individuals whose employment was involuntarily terminated from September 1, 2008 through December 31, 2009. This imposes a multitude of requirements on employers, under a tight time frame, and raises numerous questions, most of which have yet to be addressed by the Department of Labor.
