The ARRA provides a subsidy for “COBRA continuation coverage,” which is required for “group health plans.” This is the kind of COBRA coverage with which most employers are familiar. Persons enrolled both in plans covered through group insurance policies and those self-insured are eligible for the subsidy. Health Reimbursement Arrangements (HRA’s) are also covered.
The subsidy is not available for Flexible Spending Accounts (FSA) or Cafeteria Plans.
Labor and Employment Law: Current Developments 
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