While some tend to mutter the IRS’ name under their breath this time of year, kudos to the Service for providing substantial guidance on the new temporary COBRA premium subsidy enacted as part of the American Recovery and Reinvestment Act (ARRA).

In Notice 2009-27, the IRS answers lots of questions that many had regarding eligiblity for the new premium subsidy, events that qualify as “involuntary termination,” and many more topics.

One such item, whether an employer-driven reduction-in-hours qualifies as an “involuntary termination,” is answered that it is not, except if the employee then severs employment due to the reduction in hours.