The US Department of Labor has provided 2 more Fact Sheets regarding the COBRA subsidy extension. One is a Fact Sheet that provides a general explanation of the extension. The second is a Frequently Asked Questions sheet that answers some more specific questions from an employee's point of view.

I found these notices particularly useful because the introduce the concept of "transition period" as it relates to the change from 9 months to 15 months. An individual’s “transition period” is the period that begins immediately after the end of the maximum number of months (generally nine) of premium reduction available under ARRA prior to its amendment. An individual is in a transition period only if the premium reduction provisions would continue to apply due to the extension from nine to 15 months and they otherwise remain eligible for the premium reduction. Individuals in a transition period must be provided notice of the extension within 60 days of the first day of their transition period. The notice must include information on the extension from nine to 15 months and the ability to make retroactive payments for certain unpaid reduced premiums.

Neither sheet specifically addresses what happens if an individual who would otherwise be eligible for the subsidy allowed the COBRA coverage to lapse prior to November 30, 2009. But prior explanations provide that if an individual lost COBRA coverage because of expiration of eligibility (or failure to pay premiums) before exhaustion of the full 9 months and BEFORE 11/30/09, that individual cannot jump back into COBRA and get the additional 6 months. There is no new "special election period" as there was under the first subsidy bill.

Bear in mind that there will probably be further revision to the COBRA subsidy rules as we get close to the 2/28/2010 sunset of this provision, so be prepared to issue new notices as more regulation and guidance are given.