On May 18, 2021, the IRS released Notice 2021-31, a lengthy series of FAQs clarifying many aspects of the new COBRA subsidy made available under the American Rescue Plan Act of 2021 (ARPA). This allows for the following: 100% COBRA subsidy for the period of April 1, 2021 to September 30, 2021. The guidance, IRS Notice 2021-31, is predominantly in question-and-answer format. By . COBRA subsidy under the American Rescue Plan Act of 2021 Friday, April 2, 2021 The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy to assistance eligible individuals for the period of April 1, 2021 through September 30, 2021 (the “Subsidy Period”). Mere eligibility for this other coverage makes them ineligible for the credit. Under the ARPA, employers need to: 1) Identify eligible individuals; 2) Provide notice to them by May 31, 2021; 3) … As a reminder, the ARPA allows certain individuals to elect COBRA coverage and have that COBRA coverage 100% subsidized by the federal government from April 1, 2021, to September 30, 2021. The ARPA COBRA subsidy rules apply to all plans that are subject to federal COBRA. We have received a number of questions about how we are implementing the ARPA COBRA subsidy, so we wanted to give a quick update and schedule based on what we know today (4/7/21). The American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for “assistance eligible individuals,” for periods of … On March 11, 2021, President Biden signed into law the American Rescue Plan Act (ARPA). What the ARPA means for TPAs. This subsidy applies to both Federal and State COBRA programs, however there are differences in the extended … It does not necessarily address all of your specific issues. Under ARPA, however, qualified beneficiaries may instead elect prospective COBRA coverage, starting April 1, 2021, through the end of the COBRA subsidy period. The individual became eligible for COBRA coverage prior to April 1, 2021, and the period of COBRA coverage to which the individual would be entitled under federal law (18 months) overlaps with the Subsidy Period — even if the individual did not elect COBRA when it was initially offered or elected COBRA but discontinued it before April 1, 2021. It should not be construed as, nor is it intended to provide, legal advice. The American Rescue Plan Act (ARPA) has made important changes to certain qualified individuals’ COBRA premiums. On May 18, 2021, the IRS released Notice 2021-31, which contains much anticipated guidance on the American Rescue Plan Act (ARPA) COBRA premium subsidies. Under ARPA, COBRA participants must meet the below criteria in order to be an AEI: Coverage was lost due to involuntary termination of employment or reduction in hours. Section 9501 of the ARPA provides that 100% of the premiums of employees who lose health care coverage because they are involuntarily terminated (other than for gross misconduct) or have their hours of work reduced will be treated as if fully paid, beginning April 1, 2021, and ending September 30, 2021. As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”), a $1.9 trillion COVID-19 relief package, into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible employees (“Assistance Eligible Individuals” or “AEIs”) and their qualified beneficiaries from April 1, 2021, through September 30, 2021 (“Subsidy … Limited Guidance Addresses Some Issues and Includes Model COBRA Subsidy Notices. 3. BACKGROUND: THE ARPA’S COBRA SUBSIDY. On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA” or “the Act”) into law. Individuals eligible for the ARPA COBRA subsidy under the extended election period (i.e., those who previously declined or dropped COBRA, but are still within the 18-month maximum coverage period) may waive COBRA continuation coverage for any period before electing to receive COBRA subsidies, including retroactive periods of coverage beginning prior to April 1, 2021. The American Rescue Plan Act of 2021 (ARPA) provides for a 100% COBRA premium subsidy to assistance eligible individuals for the period of April 1, 2021 through September 30, 2021 (the “Subsidy Period”). ARPA makes the subsidized premiums available for the six-month period from April 1 through September 30, 2021. May 20, 2021 . What is the COBRA subsidy? This law has … ARPA contains a provision to subsidize 100% of COBRA premiums (including any applicable administrative fees) for qualifying individuals and coverage from April 1, 2021 - September 30, 2021. The American Rescue Plan Act of 2021 (ARPA) was passed through the House and Senate this week. Posted on March 29, 2021 by VantagePoint. There are 21 FAQs in the DOL’s guidance released on April 7, 2021 providing clarification on the COBRA subsidy added by the American Recue Plan Act of 2021 (ARPA). State Mini-COBRA ARPA Subsidy Obligations. Work with your COBRA vendor/administrator to determine what solution will be available. COBRA Premium Assistance under the American Rescue Plan Act of 2021 FAQs. In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming … The American Rescue Plan Act (ARPA), signed into law by President Biden on March 11, 2021, includes several provisions requiring immediate action by employers. The American Rescue Plan Act (ARPA) of 2021 included a 100 percent COBRA subsidy for workers who have been involuntarily terminated or experienced a reduction in hours. The federal American Rescue Plan Act of 2021 (ARPA) provides for a 100% subsidy of COBRA premiums for six months from April 1, 2021 through September 30, 2021, for individuals (and their covered dependents) who lose coverage under their employer’s health care plan due to a reduction in hours or involuntarily termination for reasons other than gross misconduct. ARPA defines an AEI as any individual that is a qualified beneficiary who is eligible for COBRA coverage between April 1, 2021, and Sept. 30, 2021, due to an involuntary termination of employment, if the AEI elects such coverage. ARPA of 2021: 100% Subsidy. The COBRA statute does not define “gross misconduct.” However, courts generally look at whether the employee intentionally engaged in reckless or deliberate conduct with the knowledge that the employer, a coworker, or clients/customers would suffer harm. This notice must be sent within a 30-day time period that begins 45 days before, and ends 15 days before, the date on which the COBRA subsidy will expire. Due to a variety of remaining questions surrounding the COBRA subsidies provided under the American Rescue Plan Act of 2021 (ARPA), the Hays Research and Compliance Department has put together the following compilation of frequently asked questions (FAQ). Model Notice in Connection with Extended Election Period: MS Word | PDF. There are 21 FAQs in the DOL’s guidance released on April 7, 2021 providing clarification on the COBRA subsidy added by the American Recue Plan Act of 2021 (ARPA). May 20, 2021 . Employers do not … The 18 month period is still measured from the date of the COBRA Event. For assistance-eligible individuals (AEIs), ARPA offers 100% subsidies of COBRA premiums for coverage periods from April 1, 2021 through Sept. 30, 2021. There are individuals who 1) will incur a qualifying event on or after April 1, 2021, 2) are enrolled in COBRA and paying premiums, and 3) incurred a qualifying event as far back as the end of 2019 and either did not enroll or stopped making payments. The ARPA does not address whether employers must send expiration notices to individuals who are eligible for subsidized COBRA coverage but otherwise have not elected coverage prior to September 15, 2021—the date the COBRA premium subsidy expiration notice would be due. ARPA contains a provision to subsidize 100% of COBRA premiums (including any applicable administrative fees) for qualifying individuals and coverage from April 1, 2021 - September 30, 2021. The American Rescue Plan Act, 2021 (ARPA), the third COVID-19 stimulus bill, provides COBRA premium assistance for eligible impacted workers. But what about employers? On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARPA) expanding COVID-19 relief efforts. Limited Guidance Addresses Some Issues and Includes Model COBRA Subsidy Notices. DATE: Thurs, April 15, 2021 TIME: Pacific 11:00 am to 12:30 pm Request the recording of the webinar here if you are unable to attend the live session. General COBRA FAQs for Workers. The new temporary COBRA premium subsidy was created by Section 9501 of the American Rescue Plan Act of 2021. 2021 American Rescue Plan Act . The prmiume assistance applies to periods of health coverage on or after April 1, 2021 through September 30, 2021. Employers should be busy preparing tailored COBRA … It does not necessarily address all of your specific issues. Is the COBRA subsidy is to be subsidized for the full 18 months? May 31, 2021 Deadline Approaching for ARPA’s COBRA Subsidy Election Notices Epstein Becker Green USA May 20 2021 As we previously reported, President Biden … Register Now – If registration is full, you can request the recording at the link below. COBRA administrators must determine the ramifications of ARPA on several categories of COBRA-eligible individuals. What the ARPA means for TPAs. The ARPA, signed into law on March 11, 2021, includes a temporary subsidy of 100% of COBRA premiums for those who are eligible for COBRA due to an involuntary termination of employment or a reduction in hours (referred to as “assistance eligible individuals”). The subsidy will be available for Assistance Eligible Individuals (AEIs), as determined by ARPA, from April 1, 2021 through September 30, 2021. The COBRA Premium Subsidy Law: Understanding Your Compliance Obligations. Yes. Angie and her family are eligible to receive the ARPA subsidy through September 30, 2021, when their 18-month COBRA eligibility period ends. Of course, the individual could choose to continue their COBRA coverage on a self-pay basis after Sept. 30, 2021, based on their election into COBRA to … Provided to you by … The American Rescue Plan Act of 2021 (ARPA) was signed into law on March 11, 2021. California's state continuation program is called Cal-COBRA. An employee is out on a medical leave for six months. ARPA and COBRA Subsidies. Sept. 30, 2021. Model General Notice and COBRA Continuation Coverage Election Notice: MS Word | PDF. (Yes. Although the subsidy period ends on Sept. 30, 2021, AEIs may elect to continue COBRA coverage by paying the premiums themselves up until the end of their … A six-month 100% subsidy of COBRA premiums is … The bill was signed into law on March 11, 2021. ARPA also adds one new COBRA notice – a notice advising an individual who is receiving a COBRA subsidy about the expiration of the subsidy if the subsidy terminates before September 30, 2021. COBRA Subsidy Provisions of ARPA. Treasury, Labor, and Health and Human Services (the “Departments”) regarding how the new COBRA subsidy under the American Rescue Plan Act of 2021 (“ARPA”) should be administered. By itself, the ARPA is just an outline of the COBRA subsidy, and certain federal agencies need to provide the details to enable its actual administration. Four our clients that have COBRA services through our TPA and for clients that the insurance carrier is required to manager COBRA, notices will be sent out by those providers as required by this legislation. Sept. 30, 2021 ARPA subsidy provision for COBRA premiums expires. The subsidy is available to qualified beneficiaries who are eligible for COBRA coverage due to a covered employee’s reduction in hours of employment or involuntary termination of employment. Also, the subsidy is tax-free to the participant. As your COBRA administrator, Ameriflex is committed to helping you navigate the new rules and changes to COBRA under The American Rescue Plan Act of 2021 (ARPA). The FAQs address many of the issues raised by plan sponsors since the subsidy was enacted earlier this year. Section 9501 of the ARPA provides that 100% of the premiums of employees who lose health care coverage because they are involuntarily terminated (other than for gross misconduct) or have their hours of work reduced will be treated as if fully paid, beginning April 1, 2021, and ending September 30, 2021. The premium assistance applies to periods of health coverage on or after April 1, 2021 through September 30, 2021. The FAQs address many of the issues raised by plan sponsors since the subsidy was enacted earlier this year. Congress passed the $1.9 trillion COVID relief bill on March 11, 2021. The American Rescue Plan Act of 2021 (ARPA) includes a number of provisions requiring immediate action by employers. L. No. Tzvia Feiertag, Gretchen Harders, and Jenna D. Russell . ARPA COBRA Premium Subsidy – Time for Employer Plans to Update COBRA Notices By Beth Alcalde and Amber Roberts on April 22, 2021 Posted in Employee Benefits, Employee Handbooks & Policies, Wage & Hour. It’s a 100% subsidy. The American Rescue Plan Act (ARPA) established a 100% COBRA premium subsidy for assistance eligible individuals (AEI) for the period April 1st, 2021 through September 30th, 2021. In March, we published an Alert providing a general overview of the COBRA subsidy created by the American Rescue Plan Act of 2021 (the “ARPA”). Under this new law, the federal government is covering 100% of the cost of qualifying COBRA coverage from April 1st, 2021 through September 30, 2021. Section 9501 of the American Rescue Plan Act (“ARPA”) provides temporary COBRA premium assistance for certain individuals (“Assistance Eligible Individuals” or “AEI”) by requiring that COBRA continuation coverage premiums be paid on the AEI’s behalf. It’s hard to prove.) AEIs will not receive a payment, but rather do not have to pay any of the COBRA premium for the period of coverage from April 1, 2021 through September 30, 2021. 1. The COBRA statute does not define “gross misconduct.” However, courts generally look at whether the employee intentionally engaged in reckless or deliberate conduct with the knowledge that the employer, a coworker, or clients/customers would suffer harm. Introduction. The new 100 percent premium subsidy for COBRA coverage is in effect through September 2021.

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