Our company terminated several employees on 9/1/08 who were entitled to continuing severance payments through June of 2010 (22 months). Their health insurance benefits are being continued as through they are active employees through the entire severance period. Their eligibility for cobra will begin on July 1, 2010.

Are they eligible for the cobra subsidy beginning 7/1/10 for 9 months since their actual termination date was 9/1/08 or not?

No, COBRA is based on losing insurance.

To qualify, a worker must have been involuntarily separated between Sept. 1, 2008, and Dec. 31, 2009. Workers who lost their jobs between Sept. 1, 2008, and enactment, but failed to initially elect COBRA because it was unaffordable, get an additional 60 days to elect COBRA and receive the subsidy.
This subsidy phases out for individuals whose modified adjusted gross income exceeds $125,000, or $250,000 for those filing joint returns. Taxpayers with modified adjusted gross income exceeding $145,000, or $290,000 for those filing joint returns, do not qualify for the subsidy.

They did not actually to get it till then, plus there is the requirement that they did not take it at first,

Not quite correct.

There is no requirement that you did not elect to take COBRA. If you lost your job between 9/1/08 and 12/31/09 you are entitled to the subsidy with a special open enrollment. Allowing you another chance to enroll.

Also the regulations are Federal COBRA, companies with 20 or more employees.
Some states have Mini COBRA, for 2-19 employees, and they can be same or different than the Federal regs. In addition the Mini COBRA's do not have the look back. So unless your state passes a law specifically allowing the look back the subsidy starts with those losing jobs 60 days prior to 3/1/09.