[wpseo_breadcrumb]

Legal Update Header On May 18, 2021, the IRS issued Notice 2021-31, a guidance document on the American Rescue Plan Act (ARPA) subsidy for continuation health coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA).

The Notice discusses the background of the subsidy and includes 86 questions and answers (Q&As) about its application.

[wpseo_breadcrumb]

HR Compliance Bulletin header image 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 (ARPA) 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.

[wpseo_breadcrumb]

Legal Update Header 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.

[wpseo_breadcrumb]

HR Compliance Bulletin header image The American Rescue Plan Act (ARPA), signed into law March 11, 2021, provides a 100% subsidy of premiums for employer-sponsored group health insurance continued under the Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) and similar state continuation of coverage (mini-COBRA) programs.

ARPA subsidies cover the full cost of COBRA or mini-COBRA premiums from April 1, 2021, through Sept. 30, 2021, for employees (and their qualifying family members), if the employee lost or loses group health insurance due to an involuntary job loss or reduction in work hours.

On April 28, 2020, the Departments of Labor (DOL) and the Treasury (Departments) issued deadline relief to help employee benefit plans, plan participants and plan service providers impacted by the COVID-19 outbreak.

Thereafter, on Feb. 26, 2021, DOL Disaster Relief Notice 2021-01 clarified the duration of this relief. The deadlines were initially extended by disregarding an Outbreak Period from March 1, 2020, until 60 days after the announced end of the National Emergency (or such other date announced by the Departments). Under federal law, this period could not exceed one year, meaning that the relief was expected to expire on Feb. 28, 2021.