On March 9th, the Illinois Division of Insurance published revised information regarding the American Recovery and Reinvestment Act (ARRA) and how it affects groups that are subject to Illinois state continuation, but not subject to federal COBRA continuation. Specifically, Congress revised ARRA and gave states the opportunity to allow for the special extended election period, which was not previously an option for the states. Illinois has decided to allow for the extended election.

The change means that employers subject to Illinois State Continuation will have to follow all phases of the ARRA, including allowing ex-employees who were involuntarily termed between September 1, 2008 and February 17, 2009 the ability to elect Illinois state continuation. This change does not affect Illinois spousal continuation or Illinois dependent continuation.