DOL Issues FAQs About American Rescue Plan's COBRA Subsidy
On April 7, 2021, the U.S. Department of Labor (DOL) issued answers to frequently asked questions (FAQs) about the American Rescue Plan Act’s (ARP) premium assistance for health insurance continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) and similar state mini-COBRA programs. The DOL’s FAQs are reprinted in this Compliance Bulletin.
The DOL’s new guidance on the COBRA subsidy consists of 21 FAQs, clarifying:
- New plan notice requirements for the subsidy;
- The applicability of the ARP election extension; and
- That extended deadline relief under earlier federal guidance does not apply to the ARP’s COBRA notice and election time frames.
However, the FAQs explain that the prior COBRA deadline relief does apply to an individual’s eligibility to elect the COBRA subsidy based on an earlier qualifying event.
The ARP Subsidy
The ARP provides a 100% subsidy of COBRA premiums for eligible individuals who lost group health coverage due to a reduction in hours or involuntary termination of employment. The subsidy applies from April 1, 2021, through Sept. 30, 2021, and it is available to eligible qualified beneficiaries even if they earlier declined or dropped COBRA coverage.
If you would like to register for our ARPA Compliance webinar, which will cover 100% COBRA subsidies, click here.
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