On April 7, 2021, the U.S. Department of Labor (DOL) issued FAQs and model notices for the COBRA premium assistance provisions of the American Rescue Plan Act (ARPA). The ARPA provides a 100% subsidy for employer-sponsored group health insurance continued under COBRA and similar state continuation of coverage programs for eligible individuals. The subsidy applies from April 1 through Sept. 30, 2021. The notices and the FAQs appear on a new DOL webpage dedicated to the ARPA COBRA subsidy.
Model NoticesThe new model notices released by the DOL are the following:
FAQsThe DOL guidance contains 21 FAQs on topics such as eligibility, application procedure, notice requirements and duration of the subsidy. Notably, the FAQs state that prior federal COVID-19-related relief for plan deadlines does not apply to notices or election periods set forth in the ARPA provisions about the COBRA subsidy. However, an individual may elect COBRA from an earlier qualifying event if the individual is eligible to make that election, including under the extended time frames provided under that relief. View the PDF version of the report here.
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IMPORTANT DATESMarch 11, 2021 ARPA signed into law. April 1, 2021 ARPA subsidy for COBRA premiums began. Sept. 30, 2021 ARPA subsidy for COBRA premiums expires.
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