COBRA Subsidy and dependents

Just when you think you have all your COBRA questions answered...another situation pops up!

Can someone clarify for me what happens to dependents of the AEI receiving the subsidy when they no longer are considered a dependent?  Are they only allowed to be on COBRA at the 100% rate or are they eligible for the subsidy under their own election once they lose dependent status?  Thanks!


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  • From IRS Notice 2009-27

    "Involuntary termination is the involuntary termination of employment, not the
    involuntary termination of health coverage. Thus, qualifying events other than an
    involuntary termination, such as divorce or a dependent child ceasing to be a dependent
    child under the generally applicable requirements of the plan (such as loss of dependent
    status due to aging out of eligibility), are not involuntary terminations qualifying an
    individual for the premium reduction."

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