May 31 Deadline for ARPA COBRA Subsidy Election Notices natlawreview.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from natlawreview.com Daily Mail and Mail on Sunday newspapers.
The Latest: COBRA Subsidies and New COBRA Election Rights
COBRA subsidy – Similar to legislation adopted in 2009 in response to the Great Recession, ARPA includes provisions that provide for a 100% subsidy of COBRA group health plan premiums (including premiums for continuation coverage under state mini-COBRA statutes) for assistance eligible individuals (AEIs). AEIs are qualified beneficiaries who experience a COBRA election right in connection with an involuntary termination of employment or a reduction in hours and who are (or will be) receiving COBRA coverage at any point from April 1, 2021 through September 30, 2021 (the Subsidy Period). The premium subsidy is available for COBRA coverage during the entire Subsidy Period or, if earlier, until the AEI (i) loses COBRA coverage, (ii) becomes eligible for Medicare or (iii) becomes eligible for other group health plan coverage (but not including for this purpose excepted benefits or coverage under a qualified small employer he
Q: Has the Department of Labor (DOL) issued guidance on the COBRA premium subsidy?
On March 25, we reported on the 100% federally funded COBRA premium subsidy included in the American Rescue Plan Act (ARPA), noting the need for additional guidance on a number of issues. See
FAQs on April 7, providing much needed guidance on the COBRA premium subsidy. While the FAQs provide employers with some clarity on the implementation and administration of the COBRA premium subsidy, additional guidance is still needed.
The ARPA COBRA premium subsidy provisions require employers and insurers to provide “assistance eligible individuals” (AEIs) with a 100% subsidy for premiums otherwise owed for COBRA coverage during the period from April 1, 2021 to September 30, 2021 (Subsidy Period). An AEI is a qualified beneficiary whose COBRA qualifying event is an involuntary termination of employment or reduction of hours, who is not otherwise eligible for Medicare or other group health plan coverage,
Overview of New DOL Guidance for the COBRA Subsidy Mandate – Including Helpful Charts Summarizing New Notice Requirements Wednesday, April 14, 2021
Takeaway Message. The Department of Labor (“DOL”) has recently issued model notices and forms that can be used to comply with the new subsidized COBRA requirements created by the American Rescue Plan Act of 2021 (“ARPA” or “ARP”). Plan sponsors should work promptly with their in-house benefits team, COBRA service providers, and carriers (if applicable) to discuss the distribution of these notices to ensure compliance.
Background.
On April 7, 2021, the DOL issued FAQs, model notices, and model forms for the implementation of the COBRA subsidy requirements set forth in ARPA. As discussed in more detail in our prior post, ARPA requires group health plans to provide fully-subsidized COBRA coverage to assistance eligible individuals (“AEIs”) from April 1, 2021 through September 30, 2021 (the “Subsidy
FAQs”) about COBRA Premium Assistance under the American Rescue Plan Act of 2021 (“
ARPA”). In addition to issuing the FAQs, the DOL issued model notices and announced a new website dedicated to the COBRA premium subsidy under ARPA, which can be found at the following link: https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra/premium-subsidy.
The COBRA subsidy provisions of ARPA have three major components:
It provides up to six months of fully subsidized COBRA premiums, along with certain special election rights, for eligible COBRA qualified beneficiaries;
It imposes two new notice requirements on employers; and
Importantly, provides for a corresponding tax credit for the company or entity paying for the COBRA premium subsidy.