COBRA subsidy could impact many employers
The latest COVID relief package (the American Rescue Plan Act of 2021, “ARPA”) includes a COBRA subsidy that could affect many employers. The ARPA subsidy generally requires employers to cover 100% of the cost of COBRA continuation coverage for up to six months between April 1, 2021, and September 30, 2021 (the “Subsidy Period”). These premium amounts are then reimbursable via refundable payroll tax credit.
This subsidy is not universally available, but generally applies under rules similar to the standard COBRA rules. It applies for individuals who lose coverage under a covered employer’s health care plan due to involuntary termination or reduction of hours. Similar to the standard COBRA rules, it does not apply when an employee voluntarily quits, or if an employee is fired for gross misconduct. In addition, it is purely a monetary subsidy and does not otherwise extend the length of the applicable COBRA period.
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