The US Department of Labor this morning posted an updated FAQ regarding the end of the ARRA COBRA Subsidy.  The updated FAQ clarifies that if a Qualified Beneficiary experiences a COBRA Qualifying Event on or prior to December 31, 2009, but the QB’s First Day of COBRA coverage is on or after January 1, 2010, that the QB is not eligible for treatment as an Assistance Eligible Individual.  The link to the updated FAQ is here http://www.dol.gov/ebsa/faqs/faq-cobra-arra.html.