As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible individuals (“AEIs”). As employers and plan administrators prepare to educate AEIs about this subsidy, they cannot overlook another necessary notice:
DOL Releases COBRA Premium Subsidy Model Notices – With a Few Surprises
Immediate Action Required
As discussed in our prior posts, the American Rescue Plan Act of 2021 (“ARP”) requires that plan administrators distribute new COBRA notices advising individuals of their possible rights to a COBRA premium subsidy. Yesterday, the U.S. Department of Labor released new COBRA premium subsidy model notices and FAQs explaining how that is to be done.
New COBRA election notices must now be used for all qualifying events. Also, special COBRA election notices explaining ARP rights to individuals who terminated before April 1, 2021 must be provided by May 31, 2021. Notice of termination of the availability of the subsidy might have to be provided within the next few days (depending on when an individual’s COBRA premium subsidy expires).
Plan administrators and employers have to act swiftly to ensure compliance with ARP’s COBRA notice obligations. Read below for more details about the notices and next steps.
DOL Issues Notices and Guidance on ARPA COBRA Premium Subsidy
As we previously explained in prior blogs, the American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for periods of coverage occurring between April 1 and September 30, 2021 for certain eligible individuals. Today, the U. S Department of Labor issued model notices and guidance in the form of Frequently
Some Family Members May Not Be Eligible for the ARPA COBRA Premium Subsidy
The American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for “assistance eligible individuals,” for periods of coverage occurring between April 1, 2021 and September 30, 2021, as described in earlier blog posts. An “assistance eligible individual” is any COBRA “qualified beneficiary” who loses group health coverage on