Jody Lee, Compliance Manager, Johnson & Dugan
The IRS released Notice 2009-27, which provides guidance in the form of 58 Questions and Answers with corresponding examples. Topics covered in the Notice include:
- The definition of "involuntary termination"
- Directions for calculating the premium reduction, including severance pay scenarios
- Explanation of what coverage is eligible for the subsidy
- Determination of the coverage periods.
The Notice provides welcome guidance in a number of areas. Employers should review the information to ensure that their COBRA Subsidy procedures are in compliance. Contact your Johnson & Dugan team for more information or assistance.
