Navigating the Nuances of the COBRA Subsidy Under the American Rescue Plan Act
AGG Talks: Solving Employers’ Problems - The American Rescue Plan Act’s COBRA Subsidy: What Is It and How Does It Work?
As mentioned in our prior COBRA update, the American Rescue Plan Act (ARPA) provides for government-subsidized COBRA premium payments. The subsidy is available to COBRA qualified beneficiaries who become eligible for COBRA...more
Employers and plans are reminded that they must provide a COBRA subsidy expiration notice no later than September 15, 2021, pursuant to the American Rescue Plan Act of 2021 (ARPA). ARPA had included some new COBRA obligations...more
The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's...more
The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the...more
On May 18, 2021, the IRS issued the long- awaited guidance on the COBRA subsidy and premium assistance credit available under the American Rescue Plan Act of 2021 through eighty-six questions and answers....more
As anticipated, the Internal Revenue Service (IRS) issued Notice 2021-31 (the Notice) yesterday, providing important guidance to employers and plan administrators regarding their COBRA subsidy-related obligations under the...more
Employers, if you had employees who had been on your group health plan who were involuntarily terminated or whose hours were reduced as early as November 1, 2019, read this! If those employees became eligible for COBRA and...more
On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 which contains much anticipated guidance needed to implement the COBRA subsidy provisions included in the American Rescue Plan Act of 2021 (ARPA)....more
On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARPA), which subsidizes fully paid post-employment healthcare coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA)...more
The COBRA subsidy period (April 1, 2021 – September 30, 2021) has begun and with a number of issues still outstanding, employers have no time to lose when it comes to preparing to administer the COBRA subsidy required by the...more
Notice To Employers And Group Health Plans – New COBRA Continuation Coverage Obligations And Premium Subsidies Under The American Rescue Plan Act Of 2021....more
On March 11, 2021, the American Rescue Plan Act of 2021 (the “ARPA”) was signed into law. Under Section 9501 of ARPA, employers will be required to provide a tax-free subsidy to certain employees and their qualified...more
Employers should be busy preparing tailored COBRA continuation coverage notices for certain individuals, addressing complicated election and altered COBRA premium topics that took effect only in recent weeks. Below, we offer...more
As described in our March 15, 2021 update, the American Rescue Plan Act of 2021 (the “Act”) created a temporary, 100% subsidy for assistance-eligible individuals’ premium payments for continuation health care coverage under...more
President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law on March 11, 2021. Provided here is an overview of the key features that affect employers....more
The Department of Labor recently issued FAQs addressing basic questions regarding the American Rescue Plan Act’s requirement that employers and health plans subsidize COBRA between April 1, 2021 and September 30, 2021 for...more
Last month, we advised readers of this blog to consider efforts to formalize the fiduciary governance of their health and welfare benefit plans. In that post, we described some of the reasons that employers have historically...more
The American Rescue Plan Act of 2021 (ARPA) includes a number of provisions requiring immediate action by employers. One such provision provides for a 100% federal subsidy of COBRA premiums (including the up-to-2%...more
The American Rescue Plan Act of 2021 (ARPA) requires fully subsidized COBRA premium payments for assistance eligible individuals beginning as early as April 1, 2021, and ending as late as September 30, 2021 (the Subsidy...more
For employers with group health plans, COBRA obligations under President Biden’s premiere $1.9 trillion stimulus legislation, the American Rescue Plan Act of 2021 (the “Rescue Plan”) are an early priority. ...more