Interim Report 

to 

The Congress 

on 

COBRA Premium Assistance 

Department of the Treasury 

June 2010 
Interim Report Required by ARRA

Section 3001(a)(11) of the American Recovery and Reinvestment Act of 2009 (ARRA or Act) 

requires the Secretary of the Treasury to submit an interim report to the Committee on Education 

and Labor, the Committee on Ways and Means, and the Committee on Energy and Commerce of 

the House of Representatives and the Committee on Health, Education, Labor, and Pensions, and 

the Committee on Finance of the Senate regarding the COBRA1

 premium assistance program 

contained in ARRA. Section 3001(a)(11)(A) of the Act specifies that the interim report is to 

include information on: “(i) the number of individuals provided such assistance as of the date of 

the report; and (ii) the total amount of expenditures incurred (with administrative expenditures 

noted separately) in connection with such assistance as of the date of the report.” A final report 

is due as soon as practicable after the last period for which COBRA premium assistance is 

provided, which originally was the 9-month period ending September 30, 2010 and, after several 

legislative actions extending the period, is currently the 15-month period ending August 31, 

2011, at the earliest. This document fulfills the requirement for an interim report. 

In summary, as many as two million households have benefitted from the COBRA premium 

assistance program in 2009 at a cost of slightly over $2 billion, based on the Internal Revenue 

Service’s (IRS) most recently available data. 

Background – Current Law

COBRA requires certain employers (generally those with 20 or more employees), including state 

and local governments, and certain other entities that maintain group health plans to offer 

qualified plan participants, including dependents, the opportunity to elect continued coverage 

under the group health plan for a specified period after the occurrence of certain events, such as 

termination of employment, that otherwise would cause a termination of coverage. To obtain 

COBRA continuation coverage, qualified individuals may be required to pay a premium of up to 

a maximum of 102 percent of the cost of similar coverage provided for active employees.2 An 

excise tax is imposed if a group health plan fails to comply with the COBRA continuation 

coverage rules. 

Under a separate provision of the law,3

 Federal employees and their families are also entitled to 

similar temporary continuation coverage under the Federal Employee Health Benefit Program 

(FEHBP) if coverage ends as the result of termination of employment. In addition, many states 

have laws or regulations that require continuation coverage, often for group health plans 

maintained by small employers that are not subject to the Federal COBRA continuation coverage 

requirements.4

 

1

 “COBRA” is the acronym for the Consolidated Omnibus Budget Reconciliation Act of 1985, the law that added 

the healthcare continuation coverage rules to the Internal Revenue Code (the Code) and parallel provisions in the 

Employee Retirement Income Security Act (ERISA) and the Public Health Service Act (PHS Act). 

2

 See Internal Revenue Code Section 4980B(f)(2)(C); Treasury regulation §54.4980B-8 Q&A-1. 

3

 See §8905a of title 5 of the United States Code (USC). 

4

 These programs are often referred to as “mini-COBRA” plans. Depending on state laws, qualified individuals may 

be required to pay premiums as high as 130 percent of the cost of similar coverage provided for active employees. 

1 
ARRA and subsequent legislation5

 provide a subsidy to employees who terminate employment 

involuntarily and qualify for COBRA continuation coverage as well as to their qualified family 

members. The subsidy effectively limits an individual’s cost of purchasing continuation 

coverage to 35 percent of the COBRA premium. COBRA premium assistance also applies to 

temporary continuation coverage elected under FEHBP and to comparable state-required 

continuation plans even though these later plans are not part of the original COBRA legislation. 

In general terms, the COBRA premium assistance program is administered by the IRS through 

payroll tax withholding as follows: Workers eligible for COBRA premium assistance send a 

premium payment to their employers, plan administrators, or insurers for continuation coverage 

based on the procedures in place before ARRA. Under ARRA, however, a worker’s payment 

must cover only 35 percent of the premium otherwise due. As before ARRA, the employer then 

retains the worker in its group health plan. Employers initially advance the remaining 65 percent 

to the insurer (in the case of an insured plan), and effectively are reimbursed by the IRS via 

adjusted payroll tax withholding.6 More specifically, employers (or other entities providing the 

coverage) are allowed a credit against their payroll taxes for the 65 percent of the premium that 

is not paid by the individual. 

COBRA premium assistance is limited to individuals who qualify for continuation coverage as a 

result of an involuntary termination of employment between September 1, 2008 and May 31, 

2010.7

 For some individuals who lost coverage because of an involuntary termination of 

employment between September 1, 2008 and February 17, 2009 (the date the Act was signed by 

the President), special statutory transition and notice rules allowed additional opportunities to 

elect COBRA continuation coverage, in order to make the COBRA premium assistance available 

to those who lost their jobs before passage of the Act. 

COBRA premium assistance is available for a maximum of 15 months,8 ending sooner if a 

qualified beneficiary becomes eligible for coverage under another group health plan or Medicare 

or if the period of continuation coverage otherwise ends. Eligibility for premium assistance 

begins to phase out as a taxpayer’s modified adjusted gross income for the taxable year in which 

premium assistance is provided rises above $125,000 ($250,000 for married taxpayers filing a 

joint return) and is completely phased out for those with incomes above $145,000 ($290,000 for 

married taxpayers filing a joint return). 

 

5

 The premium assistance provisions of ARRA were extended on December 19, 2009, by the Department of Defense 

Appropriations Act, 2010 (DOD Appropriations Act); on March 2, 2010, by the Temporary Extension Act of 2010 

(TEA); and on April 15, 2010, by the Continuing Extension Act of 2010 (CEA). 

6

 Individuals covered under state mini-COBRA plans send their premium payment to their insurer and their insurer 

advances the remaining 65 percent, receiving reimbursement by the IRS via adjusted payroll tax withholding. 

7

 The DOD Appropriations Act, TEA, and CEA extended the period in which involuntary terminations of 

employment causing a loss of group health coverage would qualify for assistance from December 31, 2009 to May 

31, 2010. In addition, TEA and CEA expanded the scope of the premium assistance program to include certain 

involuntary terminations occurring between March 2, 2010 and May 31, 2010, even though the employee had 

previously lost coverage due to a reduction in hours occurring between September 1, 2008 and May 31, 2010.

8

 The DOD Appropriations Act extended the duration of the premium assistance from 9 months to 15 months. 

2 
In addition to the IRS, both the U.S. Department of Labor and the U.S. Department of Health and 

Human Services have duties for administering COBRA premium assistance. The Department of 

Labor has responsibility for dealing with private sector employers with 20 or more employees, 

while the Department of Health and Human Services has responsibility for Federal, state, local 

and other non-Federal governmental plans; church plans; and other, mostly private, comparable 

state continuation plans for employers that have fewer than 20 employees. 

Individuals who are participants in plans for private sector employers with 20 or more employees 

and who are denied treatment as assistance eligible individuals and thus are denied eligibility for 

the 35 percent premium cap (whether by their plan, employer or insurer) may request an 

expedited review of the denial by the Department of Labor. The Department of Labor must 

make a determination within 15 business days of receipt of a completed request for review. The 

official application form can be filed online or submitted by fax or mail. All other individuals 

who are participants in plans whose plans, employers or insurers deny them access to premium 

assistance may request a similar review process through the Department of Health and Human 

Services. 

In addition, as required, the Department of Labor issues model notices and continues to carry out 

an outreach and education program to inform terminated employees of their rights to premium 

assistance as well as to inform employers how to comply with the new law. 

Report

COBRA premium assistance has been provided to as many as 2 million households in 2009.9

 

Because many health benefit plans cover spouses and dependents, the number of individuals 

receiving health coverage for which the COBRA premium assistance was provided is likely to be 

substantially higher than 2 million. See Table 1 for a breakout of households who receive 

assistance by state. The attached tables show the counts by state based on the address of the 

employees’ common law employer or the employer’s filing agent as provided on the IRS Form 

941. The state reported on IRS Form 941 may differ from the state in which the former 

employees receiving continuation coverage reside or previously worked. 

There is some ambiguity in the number of households that received COBRA premium assistance 

because: (1) Many, but not all, of the early filings in 2010 are likely to represent 2009 claims; 

(2) some employers may yet submit 2009 claims through amended returns filed later in 2010 (or 

perhaps even later); and (3) some former employees may have been claimed on multiple filings 

 

9

 The data contained in the attached tables were obtained from the IRS Office of Research. These data were 

processed to remove obvious errors. For instance, claims containing amounts of premium assistance that were 

inconsistent with the number of covered employees were excluded from the tabulation. This had the effect of 

reducing the aggregate amount of premium assistance by just under ten percent. Therefore, the amounts reported in 

the table may represent a slight underestimate of legitimate claims for premium assistance. The IRS expects that its 

data collection and data screening procedures will be improved over time to provide a better count in the future. 

3 
because they were covered by COBRA premium assistance for more than one quarter and their 

employers submitted claims for them in each such quarter.10 

 

Over 300,000 claims were filed by employer tax reporting units through early 2010, as shown on 

Table 2.11 These employers claimed credits for over $2 billion in premium assistance against 

payroll tax withholding, as shown in Table 3. 

Based on the IRS data, it is not possible to determine the percentage of former employees 

eligible for COBRA premium assistance who actually received the premium assistance. 

However, a study by the Treasury Department’s Office of Economic Policy concluded that 

approximately 15 percent of Unemployment Insurance (UI) beneficiaries in the state of New 

Jersey received health insurance coverage via COBRA or New Jersey continuation coverage. 

The study further estimated that between a quarter and a third of COBRA premium assistance 

eligible UI beneficiaries enrolled in subsidized continuing health insurance.12

Since inception of the subsidy program through June 3, 2010, the Department of Labor has 

received 20,199 requests for expedited review and has closed 19,715, all but 49 of which were 

adjudicated within the statutorily required 15 business day time frame. Over 13,000 of these 

reviews resulted in the employer’s determination being overturned, while the employer’s 

determination was upheld in nearly 4,300 cases. In addition, approximately 1,200 were referred 

to the Department of Health and Human Services. The remaining requests were either closed as 

incomplete applications, withdrawn by the requester, or denied because the requester had not 

applied for the premium assistance. 

Since inception of the subsidy program through the end of May 2010, the Department of Health 

and Human Services had received 3,181 requests for expedited review and had closed 3,033, all 

but 13 of which were adjudicated within the statutorily required 15 business day time frame. 

The employer’s determination was overturned in 1,393 of these cases, the employer’s 

determination was upheld in 659 cases, 503 were referred to the Department of Labor and the 

remaining were: dismissed as outside of the scope of review (52); withdrawn by the requester 

(189); or set-aside such that the requester could take more steps and reapply (237). 

The Department of Labor is also responsible for conducting outreach and education to inform the 

employees of their rights as well as inform employers how to comply with the law. Toward that 

 

10 Some employers waited until the fourth quarter (filing deadline January 31, 2010) to report their 2009 claims for 

COBRA premium assistance credits. Other employers reported claims as they occurred each quarter. Some of the 

former employees of employers that filed on a quarterly basis may have been reported in multiple quarters, resulting 

in some employees being counted more than once. The numbers in this interim report reflect payroll tax returns 

processed through April 2010. First quarter returns for 2010 were not due until April 30th, and many such returns 

have not yet been processed. Thus, the early 2010 returns reported here may not include a large number of 2010 

claims and therefore may be more properly counted as 2009 claims. 

11 Given that some employers file quarterly, there may be some multiple filings by the same employer tax reporting 

unit. 

12 The study, “COBRA Insurance Coverage Since the Recovery Act: Results from New Survey Data,” released May 

2010, is available at http://www.ustreas.gov/offices/economic-policy/cobra%20final%20report.pdf. 

4 
end, the Department of Labor developed a dedicated website (www.dol.gov/COBRA) which has 

over 70,000 subscribers and over 3 million visitors; developed a fact sheet in English and 

Spanish; developed frequently asked questions for employees and employers; conducted three 

compliance assistance webcasts with over 20,000 visitors; developed three videos including one 

in Spanish; updated publications; worked with the Department of Labor’s Employment and 

Training Administration to inform the One Stop Centers so they could help get the word out to 

dislocated workers; provided regular updates to stakeholders; and conducted 1,017 outreach 

events across the country reaching 34,341 individuals. As of the first week of May 2010, the 

Department of Labor has spent $4.2 million in administering COBRA premium assistance. 

The Department of Health and Human Services maintained a website and helpline for the public 

and provided adjudication services for terminated employees who requested review after their 

former employers denied them access to premium assistance. The Department of Health and 

Human Services continues to work with state departments of insurance to ensure that the state 

continuation coverage provisions are accurately interpreted in light of premium assistance under 

ARRA. The Department of Health and Human Services has spent $1.9 million for administering 

COBRA premium assistance.13

Because the IRS administers the processing of the COBRA credit through the payroll tax 

withholding process, the IRS costs to implement and administer the program are modest. The 

IRS estimates that it has spent less than $2 million to administer the program. In total, the cost 

of administering the COBRA premium assistance program for all three agencies combined is 

about $8 million, less than 0.5 percent of the more than $2 billion of premium assistance 

provided to date. 

 

13 This figure mainly represents contractor costs in running a helpdesk and adjudicating cases subject to review by 

the Centers for Medicare & Medicaid Services (CMS), the agency within the Department of Health and Human 

Services which has been responsible for the ARRA COBRA project. CMS has not historically employed many staff 

member experts in COBRA or other health insurance issues linked to employment. Nor has it ever created a system 

to adjudicate related matters. 

5 
2010

State 1 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Early Filings 2 Total 3

Alabama 144 2,497 5,700 7,174 397 15,912

Alaska 29 188 433 617 4 1,267

Arizona 432 5,337 15,510 17,900 1,528 40,707

Arkansas 104 2,662 7,964 3,358 128 14,216

California 1,491 24,808 58,835 87,892 4,663 177,689

Colorado 458 5,041 10,091 15,669 957 32,216

Connecticut 445 21,846 16,461 13,463 871 53,086

Delaware 24 595 4,299 1,998 80 6,996

District of Columbia 178 1,094 1,573 2,051 125 5,021

Florida 652 13,841 102,278 158,539 1,683 276,993

Georgia 361 7,102 16,147 24,990 649 49,249

Hawaii 48 920 1,385 2,163 48 4,564

Idaho 387 2,733 3,239 3,791 236 10,386

Illinois 1,506 17,909 33,298 57,359 2,052 112,124

Indiana 333 7,026 12,208 19,224 553 39,344

Iowa 442 3,825 6,532 7,526 273 18,598

Kansas 168 2,590 4,425 6,440 372 13,995

Kentucky 200 2,515 4,811 9,027 407 16,960

Louisiana 192 2,248 5,888 7,715 358 16,401

Maine 49 940 1,632 2,444 133 5,198

Maryland 316 4,436 9,176 32,207 478 46,613

Massachusetts 1,279 14,473 25,944 36,150 1,898 79,744

Michigan 1,220 15,490 23,828 40,500 2,219 83,257

Minnesota 700 13,363 23,521 32,311 1,057 70,952

Mississippi 170 1,299 2,170 2,706 190 6,535

Missouri 655 7,873 15,456 19,702 758 44,444

Montana 52 582 946 1,138 60 2,778

Nebraska 139 2,336 3,693 4,817 178 11,163

Nevada 262 2,666 4,315 5,250 356 12,849

New Hampshire 193 1,704 3,483 6,067 347 11,794

New Jersey 879 10,251 27,165 37,186 1,637 77,118

New Mexico 26 486 798 1,119 51 2,480

New York 2,011 22,366 40,710 61,793 3,273 130,153

North Carolina 561 11,547 22,054 36,703 978 71,843

North Dakota 132 563 1,312 1,753 56 3,816

Ohio 941 13,941 29,115 43,209 1,879 89,085

Oklahoma 290 2,193 3,584 5,046 235 11,348

Oregon 911 7,794 10,557 19,413 766 39,441

Pennsylvania 1,513 22,808 31,904 47,605 3,481 107,311

Rhode Island 133 1,499 4,336 5,265 308 11,541

South Carolina 311 2,880 5,265 6,490 230 15,176

South Dakota 38 474 1,060 1,209 48 2,829

Tennessee 519 5,145 15,650 17,720 506 39,540

Texas 1,175 25,308 43,473 58,817 1,447 130,220

Utah 222 2,818 4,285 6,133 395 13,853

Vermont 49 477 755 904 34 2,219

Virginia 608 6,602 13,272 19,919 724 41,125

Washington 520 8,038 14,648 21,367 1,100 45,673

West Virginia 25 341 853 1,022 29 2,270

Wisconsin 1,235 14,799 16,651 23,100 1,723 57,508

Wyoming 4 225 417 489 50 1,181

Other 4 46 1,014 1,967 4,025 26 7,078

Grand Total 24,774 351,508 715,072 1,050,475 42,030 2,183,859

Notes

1 The state is determined by the address of the employer reporting entity provided on the IRS Form 941.

Data Sources

Table 1

2009

2 The early filings for 2010 includes some employers claiming the COBRA premium assistance during 2009 and some the claiming the COBRA premium assistance 

in the first quarter of 2010. Processing of the IRS Forms 941 claiming COBRA premium assistance for the first quarter 2010 was not yet complete.

Number of Households with Premium Assistance

3 The total may count a household more than once if the eligible individual is claimed in more than one quarterly return.

Internal Revenue Service Office of Research - Compliance Data Warehouse - BMF Transaction History File

Extracted Data File - Business Master File - F941 Data - Processing Cycles 201001 - 201017

Processed through April 2010.

4 Other including Army PO, Pacific, Guam, Puerto Rico, Virgin Islands. The category also includes Wyoming for the first quarter 2009 and Alaska for the early 

filings for 2010 to prevent disclosure of tax information.

6 
2010

State 2 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Early Filings 3 Total

Alabama 48 650 1,150 1,466 154 3,468

Alaska 18 84 138 190 4 430

Arizona 234 1,397 1,838 2,318 380 6,167

Arkansas 40 398 557 673 64 1,732

California 708 6,198 9,385 12,907 1,532 30,730

Colorado 299 1,546 2,194 2,604 382 7,025

Connecticut 240 1,348 1,736 2,284 360 5,968

Delaware 15 151 281 335 39 821

District of Columbia 34 278 383 501 67 1,263

Florida 321 2,973 4,626 5,775 576 14,271

Georgia 182 1,416 2,373 2,957 220 7,148

Hawaii 17 277 387 514 18 1,213

Idaho 58 402 554 624 76 1,714

Illinois 773 4,092 5,595 7,063 750 18,273

Indiana 164 1,365 1,976 2,498 233 6,236

Iowa 175 932 1,310 1,558 150 4,125

Kansas 81 838 1,210 1,465 171 3,765

Kentucky 95 791 1,130 1,463 158 3,637

Louisiana 122 750 1,104 1,338 180 3,494

Maine 35 282 472 656 60 1,505

Maryland 197 1,325 1,846 2,473 214 6,055

Massachusetts 626 2,934 3,889 4,957 730 13,136

Michigan 440 3,220 4,245 5,327 662 13,894

Minnesota 317 2,048 2,878 3,597 416 9,256

Mississippi 77 408 559 683 76 1,803

Missouri 361 1,778 2,379 2,977 361 7,856

Montana 17 190 285 330 36 858

Nebraska 70 455 606 823 80 2,034

Nevada 133 753 942 1,118 135 3,081

New Hampshire 135 650 856 1,032 151 2,824

New Jersey 485 2,730 3,808 5,167 651 12,841

New Mexico 17 176 265 337 24 819

New York 1,013 5,371 7,277 9,728 1,367 24,756

North Carolina 269 2,073 2,873 3,615 294 9,124

North Dakota 62 197 289 322 32 902

Ohio 416 3,126 4,492 5,870 733 14,637

Oklahoma 113 645 907 1,073 123 2,861

Oregon 394 1,704 2,106 2,526 291 7,021

Pennsylvania 693 4,249 5,865 7,396 980 19,183

Rhode Island 73 453 578 716 103 1,923

South Carolina 178 888 1,243 1,464 98 3,871

South Dakota 18 185 309 348 28 888

Tennessee 186 1,203 1,840 2,314 159 5,702

Texas 541 3,891 5,454 6,768 567 17,221

Utah 109 636 899 1,088 129 2,861

Vermont 27 212 281 326 22 868

Virginia 327 1,807 2,670 3,362 346 8,512

Washington 270 2,224 2,960 3,659 377 9,490

West Virginia 14 103 210 261 12 600

Wisconsin 459 2,422 3,037 3,803 478 10,199

Wyoming 4 103 130 151 27 411

Other 4 26 212 370 458 13 1,079

Grand Total 11,722 74,539 104,747 133,258 15,285 339,551

Notes

2 The state is determined by the address of the employer reporting entity provided on the IRS Form 941.

Data Sources

Extracted Data File - Business Master File - F941 Data - Processing Cycles 201001 - 201017

Processed through April 2010

1 The number of IRS Forms 941 filed by common law employers or the employers’ filing agent on which a COBRA premium assistance was claimed. A 

single corporation or organization may have more than one employer reporting unit filing an IRS Form 941 in a quarter.

3 The early filings for 2010 includes some employers claiming the COBRA premium assistance during 2009 and some the claiming the COBRA premium 

assistance in the first quarter of 2010. Processing of the IRS Forms 941 claiming COBRA premium assistance for the first quarter 2010 was not yet 

complete.

2009

Number of Employer Returns 1

Table 2

Internal Revenue Service Office of Research - Compliance Data Warehouse - BMF Transaction History File

4 Other including Army PO, Pacific, Guam, Puerto Rico, Virgin Islands. The category also includes Wyoming for the first quarter 2009 and Alaska for 

the early filings for 2010 to prevent disclosure of tax information.

7 
2010

State 1 1st Quarter 2nd Quarter 3rd Quarter 4th Quarter Early Filings 2 Total

Alabama 58,021 2,043,573 5,164,609 7,422,321 409,652 15,098,176

Alaska 13,726 202,550 483,633 961,758 3 1,661,666

Arizona 150,828 4,083,605 10,230,040 15,426,392 1,516,000 31,406,865

Arkansas 32,299 1,721,405 13,740,895 2,597,249 103,115 18,194,962

California 594,403 24,520,498 66,327,766 128,940,452 5,048,837 225,431,955

Colorado 176,557 5,060,102 10,840,650 17,857,083 1,018,775 34,953,167

Connecticut 222,321 5,305,596 12,105,572 23,101,602 1,102,886 41,837,977

Delaware 12,335 775,271 5,008,050 2,387,447 96,680 8,279,783

District of Columbia 28,696 797,237 1,763,984 2,822,700 154,674 5,567,290

Florida 238,277 12,812,456 36,991,778 57,060,069 1,757,741 108,860,321

Georgia 127,330 5,922,272 16,812,098 29,965,787 636,513 53,464,001

Hawaii 17,189 610,432 1,119,447 1,715,527 42,689 3,505,285

Idaho 114,018 1,723,359 2,608,076 3,246,331 223,520 7,915,304

Illinois 629,495 17,555,949 35,441,315 61,036,368 2,505,806 117,168,933

Indiana 142,053 5,444,682 15,492,514 23,556,440 676,237 45,311,928

Iowa 169,451 3,351,167 6,583,685 7,777,589 244,015 18,125,907

Kansas 57,912 2,197,930 4,341,126 8,235,157 335,427 15,167,552

Kentucky 58,530 1,997,502 4,344,723 10,139,435 372,629 16,912,818

Louisiana 79,932 1,814,965 3,836,566 6,982,451 325,325 13,039,238

Maine 19,193 721,004 1,782,734 3,326,924 169,186 6,019,040

Maryland 131,852 4,110,617 9,833,894 17,233,616 537,270 31,847,249

Massachusetts 655,754 13,915,098 32,471,134 52,750,262 2,534,224 102,326,472

Michigan 524,833 13,149,750 25,475,205 38,623,501 2,541,853 80,315,142

Minnesota 251,725 10,478,358 25,019,022 34,591,095 1,187,094 71,527,294

Mississippi 54,776 1,030,891 2,069,595 2,898,169 136,007 6,189,438

Missouri 219,878 6,203,187 12,170,775 18,794,927 748,083 38,136,851

Montana 16,444 609,313 1,005,069 1,243,795 68,152 2,942,774

Nebraska 51,859 2,237,215 3,593,008 5,201,621 187,639 11,271,341

Nevada 89,570 2,295,358 4,534,330 5,178,213 356,127 12,453,598

New Hampshire 94,617 1,943,921 4,813,651 6,480,963 428,274 13,761,427

New Jersey 457,649 10,121,975 30,815,441 56,007,323 2,073,812 99,476,199

New Mexico 14,126 428,808 817,883 1,189,036 71,371 2,521,224

New York 935,212 19,482,743 46,663,463 84,295,252 4,063,781 155,440,451

North Carolina 208,745 9,682,231 19,934,867 35,628,593 896,814 66,351,250

North Dakota 45,886 467,075 1,402,650 2,218,632 48,155 4,182,398

Ohio 354,609 11,668,140 24,811,223 48,507,591 1,921,132 87,262,696

Oklahoma 95,616 1,843,661 3,468,818 5,021,010 257,455 10,686,559

Oregon 334,892 6,542,894 9,721,693 18,993,097 757,543 36,350,118

Pennsylvania 551,565 16,766,941 32,876,538 55,034,776 3,541,063 108,770,884

Rhode Island 65,859 1,563,588 4,476,870 6,024,471 374,517 12,505,305

South Carolina 111,703 2,516,726 4,817,045 7,153,147 236,450 14,835,072

South Dakota 14,466 389,865 1,042,495 1,100,080 39,291 2,586,197

Tennessee 164,426 4,276,299 14,388,068 20,188,792 535,496 39,553,081

Texas 511,113 21,641,178 43,049,077 65,244,184 1,602,577 132,048,129

Utah 104,079 2,174,722 4,292,554 6,720,807 431,424 13,723,587

Vermont 16,724 386,579 778,346 1,083,264 38,002 2,302,915

Virginia 247,386 5,749,316 13,426,387 21,869,983 750,352 42,043,423

Washington 191,903 7,340,882 15,943,477 23,366,096 1,135,822 47,978,180

West Virginia 11,745 326,938 999,970 1,253,861 40,166 2,632,680

Wisconsin 393,365 9,938,608 16,394,156 25,725,238 1,449,838 53,901,206

Wyoming 3 289,669 387,996 583,055 69,258 1,329,978

Other 3 15,949 518,057 1,403,471 2,898,365 22,007 4,857,849

Grand Total 9,880,892 288,752,160 667,917,429 1,087,661,894 45,820,756 2,100,033,132

Notes

1 The state is determined by the address of the employer reporting entity provided on the IRS Form 941.

Data Sources

3 Other including Army PO, Pacific, Guam, Puerto Rico, Virgin Islands. The category also includes Wyoming for the first quarter 2009 and Alaska for the 

early filings for 2010 to prevent disclosure of tax information.

2009

COBRA Premium Assistance

($ Amount)

Processed through April 2010

Internal Revenue Service Office of Research - Compliance Data Warehouse - BMF Transaction History File

Extracted Data File - Business Master File - F941 Data - Processing Cycles 201001 - 201017

Table 3

2 The early filings for 2010 includes some employers claiming the COBRA premium assistance during 2009 and some the claiming the COBRA premium 

assistance in the first quarter of 2010. Processing of the IRS Forms 941 claiming COBRA premium assistance for the first quarter 2010 was not yet 

complete.

8