The Centers for Medicare and Medicaid Services and the Employee Benefits Security Administration are hurrying to roll out an appeal form needed to implement the new COBRA health benefits continuation subsidy program.

CMS, an arm of the U.S. Department of Health and Human Services, and EBSA, an arm of the U.S. Labor Department, are seeking emergency Office of Management and Budget approval of the form that workers will use to ask for expedited reviews of premium assistance denials.

A sectionof the new American Recovery and Reinvestment Act sets out complicated rules for deciding which involuntarily terminated employees are and are not eligible to have 65% of COBRA health benefits continuation premiums reimbursed by the federal government.

HHS and the Labor Department are supposed to act on eligibility denial appeal requests within 15 business days.

CMS is estimating its parent might get 12,000 requests for reviews, and EBSA is requesting its parent might get 95,000 requests for reviews.

Public comments on the forms are due May 14, and the agencies are asking OMB to approve the forms by May 15.

The agencies are seeking OMB approval because of a federal law that requires federal agencies to get OMB approval to adopt new forms and to submit existing forms to regular public comment periods.