arpa cobra subsidy eligibility

Model ARPA notices were published on April 12, 2021 and must be provided to eligible individuals no later than May 31, 2021. Employers and plans must provide the notices within the time frames specified in ARPA, and AEIs must elect COBRA coverage within 60 days of the notice date to receive the premium subsidy. By May 31, 2021, employers must provide notice of the COBRA subsidy (and certain other COBRA rights under ARPA) to AEIs who first became eligible to elect COBRA before April 1, 2021and have not reached the maximum period for their COBRA coverage (18 months) and/or did not elect COBRA coverage when it was first offered. Eligibility determination, notification of eligible members and Employer tax credit processes are pending additional guidance from the DOL. Employers were reimbursed the 65 percent via a federal tax credit. COBRA Subsidy Plan Requirements New notice requirements using government models (subsidy availability, subsidy expiration) Extended election opportunity for assistance eligible individuals without COBRA election in effect of as April 1, 2021 Plan/plan sponsor receives subsidy through payroll tax credit (refundable and advanceable) The ARPA provides an Assistance Eligible Individual who is not enrolled in COBRA as of April 1, 2021 a second window of time to enroll in order to take advantage of the subsidy. The American Rescue Plan Act of 2021 (ARPA) includes a number of provisions requiring immediate action by employers. Who is an Assistance Eligible Individual (AEI)? One such provision provides for a 100% federal subsidy of COBRA premiums (including the up-to-2% administrative fees) during the period of April 1, 2021, through September 30, 2021. As such, during the Subsidy Period, individuals who are eligible for the COBRA subsidy are not required to pay their COBRA premium. Some of your client’s members may not owe premiums for April 2021 through September 2021. The American Rescue Plan Act of 2021 (“ARPA”) includes a 100% COBRA premium subsidy for “assistance eligible individuals,” for periods of … This subsidy requirement generally applies to group health plans that are subject to the COBRA provisions found in the Employee Retirement Income Security Act, Internal Revenue Code or the Public Health Service Act. The COBRA premium assistance is available for “assistance eligible individuals (AEIs).” An AEI is a COBRA qualified beneficiary who is eligible for COBRA by reason of a qualifying event that is a reduction in hours or an involuntary termination of employment, and elects COBRA continuation coverage. 1 Individuals who are eligible for COBRA because of voluntary termination, retirement or death would not qualify as assistance eligible individuals. 1 This premium assistance is applicable from April 1, 2021 to September 30, 2021. While not exhaustive, the Notice covers a broad range of questions and answers that clarify the … Blue Shield of California FAQs. Not Eligible for ARPA COBRA Subsidy If eligible, the employer will be billed for the COBRA premiums between 4/1/21 to 9/30/21, unless COBRA eligibility ends sooner. Assistance eligibility includes AEIs who: To qualify as an AEI under ARPA, the COBRA participant must meet ALL of the following: The QE was either Involuntary Termination, or Reduction in Hours. The ARPA COBRA subsidy applies to certain individuals (referred to as “assistance eligible individuals” or AEIs) whose COBRA qualifying event was an involuntary termination of employment or a reduction in hours of employment. A Model General ARPA COBRA Notice– to L. 117-2, 135 Stat. The subsidy is available to qualified beneficiaries who are eligible for COBRA coverage due to a covered … The IRS has provided guidance on the premium assistance and tax credit under the American Rescue Plan Act of 2021 (ARPA) for continuation health coverage under COBRA. Definition of COBRA Payment. COBRA Payment means that portion of the Separation Pay that does not constitute the base benefit or variable benefit. Examples of COBRA Payment in a sentence. Such Special Severance Payment shall end upon expiration of the COBRA Payment Period. For example, if an employee was involuntarily terminated in August 2020 and did not elect COBRA coverage, he or she would still be within their COBRA … The ARPA COBRA subsidy rules only apply to assistance eligible individuals who were enrolled in employer health plans at the time of their involuntary termination or reduction in hours. The new COBRA election for April 1 events and forward should include plenty of information about the ARP Premium Assistance, and explain what the ARPA is. The COBRA subsidy is a result of the passage of the American Recovery and Reinvestment Act or ARRA. The COBRA subsidy is only available to individuals who were involuntarily terminated. 0 Comments. In other words, the ARPA’s COBRA subsidy provisions do not extend the period of COBRA continuation coverage for which a person would otherwise be eligible. Former employees are eligible for the ARPA subsidy only when COBRA coverage is in effect when both the qualifying event (i.e., involuntary termination of employment) and the effective date of the COBRA coverage occurs between November 1, 2019 and September 30, 2021. 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 … Under the American Rescue Plan Act (“ARPA”), any assistance eligible individual shall be treated as having paid the full amount of the COBRA premium from April 1, 2021 through September 30, 2021. New ARPA/COBRA Subsidy. Eligibility for the ARPA COBRA Subsidy Which individuals are eligible for the COBRA subsidy? Sponsors of group health plans have new responsibilities following the passage of the American Rescue Plan Act (“ARPA”) on March 11, 2021. Premium Assistance for COBRA Benefits . One of the many lifelines for workers in the American Rescue Plan Act of 2021 (ARPA) is a new COBRA subsidy that completely covers the cost of continuation coverage for qualifying individuals from April 2021 through September 2021. Outside of regulation, it is permissible for an employer to extend COBRA benefits. However, simply being permissible is not usually enough for a business to decide whether or not it will make the decision to do so. Any reduction in hours, including an employee’s voluntary reduction in hours, that results in a loss of eligibility will qualify for the ARPA COBRA subsidy. Employers and plan administrators will be paying subsidies for COBRA premiums, which can claimed back in tax credits. By: Lawrence J. Finnell On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 (Notice) which provides additional guidance and clarifications concerning the new COBRA premium assistance (“premium assistance” or “subsidies”) provisions enacted under the American Rescue Plan Act of 2021 (ARPA). IRS Issues Comprehensive Guidance Regarding ARPA COBRA Subsidy . One such benefit is the COBRA Subsidy for Assistance Eligible Individuals (AEIs). On May 18, 2021, the IRS published Notice 2021-31 (the Notice), providing long-awaited guidance on the temporary Consolidated Omnibus Budget Reconciliation Act (COBRA) premium assistance 1 (COBRA subsidy) established by the American Rescue Plan Act of 2021 2 (ARPA or the Act). Those posts were primarily focused on the federal COBRA laws, which generally apply to ERISA group health plans maintained by private-sector employers with twenty or more employees and … The ARPA doesn’t provide any language regarding the citizenship of the employee. Mere eligibility for this other coverage makes them ineligible for the credit. First, health plans and issuers must notify qualified beneficiaries and Assistance Eligible Individuals regarding the premium assistance provided by the ARPA. This includes Assistance Eligible Individuals who never made a COBRA election in the first place or who made an election but later dropped COBRA. ARPA offers relief by providing a federal subsidy equal to the entire COBRA premium cost for up to six months from April 2021 through September 2021. Who is eligible for the subsidy? Note that the model notices issued by the DOL indicate that eligibility for coverage does not include time spent in a waiting period. The DOL provided all three of these notices (plus one additional model notice) ahead of the statutory deadline. dependent) are not eligible for premium assistance. Premium repayment. Notice 2021-31 This notice provides guidance on the application of § 9501 of the American Rescue Plan Act of 2021 (the ARP), Pub. For assistance-eligible individuals (AEIs), ARPA offers 100% subsidies of COBRA premiums for coverage periods from April 1, 2021 through Sept. 30, 2021. The ARPA COBRA subsidy is available to “assistance eligible individuals” (AEIs), generally defined as employees who were involuntarily terminated, or who experienced a reduction in hours, as well as their covered dependents. 4 (March 11, 2021), relating to temporary premium assistance for Consolidated Omnibus Budget Reconciliation Act of 1985 ( COBRA) continuation coverage. It should inform qualified beneficiaries of the subsidy, explain who is eligible, and for how long. The ARPA provides for a 100% COBRA premium subsidy. Involuntary Termination & Eligible for ARPA COBRA Subsidy. On May 18, 2021, the IRS issued guidance that provides greater clarity to employers administering the new premium assistance requirements under ARPA. To be eligible for the premium assistance, you: MUST have a COBRA qualifying event that is a reduction in hours or an involuntary termination of a covered employee’s employment; MUST Under the ARPA, assistance eligible individuals (as further described below) may have 100% of their COBRA or state continuation premiums subsidized, for a period no longer than six months (April 1, 2021 through September 30, 2021). Under the COBRA ARPA subsidy rules, COBRA covered individuals are required to notify the employer if they become eligible for other group coverage or Medicare. Individual is laid off in May 2021. If you are an employer or business, the COBRA provision of the APRA has several implications. As set forth in ARPA, an AEI is an individual who: Loses eligibility for coverage due to a reduction in hours or involuntary termination of employment (other than by … eligible for COBRA or mini-COBRA continuation coverage because of the covered employee’s involuntarytermination (unrelated to gross misconduct) or reduction in hours of employment. The job loss or reduction in hours does not need to be COVID-related. ARPA establishes a 100% COBRA premium subsidy for eligible individuals during the period beginning on April 1, 2021 and ending on September 30, 2021. ® Summary of the COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021 President Biden signed H.R. The ARPA Subsidy applies only to coverage for Assistance Eligible Individuals (AEI). For assistance-eligible individuals (AEIs), ARPA offers 100% subsidies of COBRA premiums for coverage periods from April 1, 2021 through Sept. 30, 2021. Notice 2021-31 2 contains 86 questions and answers pertaining to the administration of the ARPA COBRA premium subsidy, including: Eligibility for premium assistance How long will the ARPA COBRA subsidy last? The COBRA subsidy will be available beginning on April 1, 2021 and end on September 30, 2021. COBRA premium assistance credit under ARPA clarified. The ARPA, among other things, makes significant changes to COBRA administration by providing for additional COBRA enrollment rights and a temporary 100% COBRA premium subsidy from April 1, 2021 to September 30, 2021. ARPA Premium Assistance. An AEI must meet all the following conditions: The ARPA COBRA Assistance program limits assistance to those eligible for COBRA, unless the eligibility was due to the voluntary termination of employment by the employee. The U.S. Department of Labor (DOL) has already produced model notice forms and initial … Employers typically provide the COBRA premium assistance and seek reimbursement by claiming a tax credit on their quarterly employment taxes. The ARPA provides 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”). subsidizes the full COBRA premium for “Assistance Eligible Individuals” for periods of coverage from April 1, 2021 through September 30, 2021. The subsidies are tax-free to ex-employees and employers can recoup costs through a payroll tax credit. The guidance consists of 86 Q&As on the ARPA COBRA premium assistance provisions and covers topics such as who is eligible for the premium subsidy, when a … This premium assistance is applicable from April 1, 2021 to September 30, 2021. Duration of the Subsidy Period The duration of the subsidy period is from April 1, 2021 to September 30, 2021. T he new 100 percent premium subsidy under the American Rescue Plan Act (ARPA) applies to individuals eligible for COBRA coverage due to either a … ARPA COBRA Subsidy FAQs Are all COBRA-standard Qualifying Events (QEs) eligible for the ARPA Subsidy? Under ARRA, the COBRA subsidy covered 65 percent of the premium, leaving the Assistance Eligible Individual (AEI) to pay 35 percent. The subsidy will be available for Assistance Eligible Individuals (AEIs), as determined by ARPA, from April 1, 2021 through September 30, 2021. If you use isolved Benefit Services for COBRA administration, isolved Benefit Services will notify assistance eligible individuals on the employer’s behalf. ProBenefits Compliance Webinar on ARPA COBRA subsidy … Though the DOL has released new Model COBRA Notices and FAQs, many unanswered questions remain. The ARPA provides a 100% subsidy for COBRA premiums for medical plans for qualified beneficiaries who are either: 1) currently enrolled in COBRA or become COBRA eligible after April 1, 2021; 2) eligible but didn’t enroll previously and are still within their 18-month period; or. The ARP makes the premium assistance available for “Assistance Eligible Individuals.” An Assistance Eligible Individual is a COBRA qualified beneficiary who meets the following requirements during the period from April 1, 2021 through September 30, 2021: • Is eligible for COBRA continuation coverage by reason of a qualifying event that is a The ARPA subsidy covers the full cost of COBRA or mini-COBRA premiums from April 1 – Sept. 30, 2021, for “assistance-eligible individuals.” Covered Plans. A. ARPA provides a second opportunity for an assistance-eligible individual who is still within their COBRA maximum period (18 months from the qualifying event or loss of coverage, depending on plan design) to prospectively elect COBRA continuation coverage. 1. 1. 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. Beginning April 1, 2021, the recently passed American Rescue Plan Act (“ARPA” or the “Act”) will require covered employers to pay state or federal health insurance continuation expenses (referred to as “COBRA”) for eligible separated employees for up to six months. The bill includes a federal subsidy that will cover 100% of the cost of COBRA continuation coverage for up to 6 months for individuals who have had an involuntary termination of employment or reduction in hours who have federal or state continuation of coverage rights. The ARPA COBRA premium subsidy provisions require employers and insurers to provide "assistance eligible individuals" (AEIs) with a 100% subsidy for premiums otherwise owed for COBRA coverage during the period from April 1, 2021 to September 30, 2021 (Subsidy Period). The American Rescue Plan Act (ARPA) is aimed at providing COVID-19 relief and included significant impacts for employee benefits. Unlike the 2009 ARRA subsidy provisions, however, ARPA includes reduction in hours of employment as one of the qualifying events that trigger eligibility for the COBRA subsidy. Model ARPA notices were published on April 12, 2021 and must be provided to eligible individuals no later than May 31, 2021. COBRA expiration date: 12/31/2022. (QA-20) The COBRA enrollee also has the option to enroll in different The assistance eligible individuals (AEIs) will pay nothing for COBRA coverage. Under ARPA, an assistance eligible individual (“AEI”), which is a COBRA qualified beneficiary (“COBRA QB”) who becomes eligible for COBRA due to a reduction in hours or involuntary termination of employment, may be eligible for a COBRA subsidy equal to the entire COBRA premium for the period from April 1, 2021 through September 30, 2021. Among other provisions, ARPA includes a 100% COBRA subsidy for up to six months for individuals who lost health coverage because of involuntary termination or reduction of hours during the pandemic. As we previously explained in our prior blogs, both here and here, on the new COBRA subsidy rules, 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. Federal government websites often end in .gov or .mil. IRS Guidance on New COBRA Subsidy Clarifies Many Outstanding Questions. With ARPA, the COBRA subsidy will cover 100 percent of the AEI’s COBRA premium. If you use isolved Benefit Services for COBRA administration, isolved Benefit Services will notify assistance eligible individuals on the employer’s behalf. A year after the onset of the Coronavirus pandemic, The American Rescue Plan Act (ARPA) established the second ever COBRA premium subsidy for continuation coverage.... (group health coverage) from April 1, 2021 through September30, 2021. eligible for COBRA or mini-COBRA continuation coverage because of the covered employee’s involuntarytermination (unrelated to gross misconduct) or reduction in hours of employment. Get more information. The new model notices are: 1. The .gov means it’s official. Examples of COBRA / Cal-COBRA eligibility exceeding 18 month eligibility window include: Small Groups (2-19) – up to 36 months of Cal-COBRA coverage Small Groups (20+) / Large Groups – Federal COBRA beyond 18 months, with qualifying extension June 1, 2021. The IRS recently issued Notice 2021-31, which provides much sought-after detail regarding the contours and operation of the temporary premium subsidy for COBRA continuation coverage available through the American Rescue Plan Act of 2021 (ARPA).. As enacted on March 11, the basic mechanics of the COBRA premium subsidy under ARPA are as follows: “assistance eligible … Because COBRA premium assistance payments (discussed above) are eligible for 100 percent reimbursement via a payroll tax credit, such costs may not be included in PPP forgivable payroll costs. COBRA Changes Under the American Rescue Plan Act (ARPA) Under COBRA, an individual who was covered by a group health plan on the day before the occurrence of a qualifying event (such as a termination of employment or a reduction in hours that results in loss of coverage under the plan) may be able to elect COBRA continuation coverage upon that qualifying event. DOL’s ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More ... which contains information on the subsidy and forms for individuals to attest to meeting the conditions for eligibility … In our most recent summary of IRS Notice 2021-31, we noted the Internal Revenue Service provided much-needed clarity to looming … Here’s what you need to know about this important health insurance assistance. The ARPA COBRA premium subsidy provisions feature three new notice requirements. Under ARPA, employers are required to offer a 100% subsidy to eligible individuals for a specified time period. IRS Provides Clarity on ARPA COBRA Subsidy Impact on State “Mini-COBRA” Plans By Joy M. Napier-Joyce and Brian M. Johnston on May 23, 2021. ARPA establishes a 100% COBRA premium subsidy for certain assistance eligible individuals (AEIs) during the period beginning on April 1, 2021 (the first day of the first month beginning after the bill is signed by the President), and ending on September 30, 2021. The ARPA makes the premium assistance available to qualified individuals who meet the specific requirements during the period from April 1, 2021 through September 30, 2021. As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”) 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 Period”). Employers and plan administrators will be paying subsidies for COBRA premiums, which can claimed back in tax credits. May 19, 2021. The ARPA Subsidy applies only to coverage for Assistance Eligible Individuals (AEI). Steps Your Team Can Take . 1319, the American Rescue Plan Act of 2021 (ARP), on March 11, 2021. However, the relief does not apply to the COBRA subsidy notices or related election periods. By Paul Bonner. Subsidy eligibility does not extend or alter the original maximum period of COBRA eligibility. The ARPA requires a 100% COBRA subsidy for certain individuals beginning April 1, 2021, through September 30, 2021. To get the subsidy, the individual’s maximum COBRA eligibility period must also not have expired as of April 1, 2021. We have previously written blog posts on the COBRA subsidy added by ARPA, the follow-up FAQs that were recently issued, and the new notice requirements for the COBRA subsidy. April 2021. Neither the ARPA nor the DOL FAQs clarify whether a former employee who is subject to a waiting period is “eligible” for other coverage and therefore not eligible for the COBRA subsidy. This 100% COBRA subsidy is provided for the period April 1, 2021 to September 30, 2021. COBRA reimbursements are not taxable if you’re required to prove to your former employer that you made the COBRA payments before they reimburse you. You should keep documentation of any arrangement you have with your former employer and for each COBRA payment you’ve made and each reimbursement you received. Note: This blog was originally published in March 2021 and has been updated … Home > COBRA Subsidy > IRS Provides Clarity on ARPA COBRA Subsidy Impact on State “Mini-COBRA” Plans. ARPA of 2021: 100% Subsidy. Subsidy eligibility: 6/1/2021 – 9/30/2021. Employers typically provide the COBRA premium assistance and seek reimbursement by claiming a tax credit on their quarterly employment taxes. Late premium payments for retroactive COBRA coverage – an AEI will remain subsidy eligible for COBRA coverage effective on or after April 1, 2021 even if they elected retroactive COBRA coverage under the deadline relief notices (e.g., Outbreak Period) and they stopped paying their retroactive COBRA coverage premiums. Under ARPA, an assistance eligible individual (“AEI”), which is a COBRA qualified beneficiary (“COBRA QB”) who becomes eligible for COBRA due to a reduction in hours or involuntary termination of employment, may be eligible for a COBRA subsidy equal to the entire COBRA premium for the period from April 1, 2021 through September 30, 2021. ARPA does not define what constitutes a voluntary or involuntary termination, so eligibility will depend on the individual facts and circumstances. THE ARPA COBRA SUBSIDY. The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it applies for the period from April 1, 2021, to September 30, 2021. The U.S. Department of Labor (DOL) issued guidance under the American Rescue Plan Act of 2021 (ARPA) and provided model notices to assist employers with fulfilling their employer notice obligations with respect to the new COBRA subsidy made available under ARPA to Assistance Eligible Individuals (AEIs) during the period April 1, 2021 through September 30, 2021 (the Subsidy Period). 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. Eligible individuals pay nothing, and employers receive a tax credit through quarterly payroll tax returns. Under ARPA, certain participants and beneficiaries of employer-sponsored health plans are eligible for a federal subsidy, which will cover for a limited period 100% of the premium for COBRA continuation coverage. The subsidy is in effect until September 30, 2021. We have compiled this list of frequently asked questions about … An involuntary termination of employment means “a severance from Here you will find the latest ARPA regulatory updates, OCA’s COBRA process changes, and more, so that our clients are up to date will all the changes taking place. 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). American Rescue Plan Act COBRA FAQs. ( Caution: As a general matter, employers rarely satisfy the difficult factual threshold required to invoke COBRA’s gross misconduct rule.) The first notice is required to inform Assistance Eligible Individuals (AEIs) of the availability of the subsidy and of the option to enroll including the option to enroll in … To assist SHBP with complying with the ARPA, we require our Employing Entities to identify AEIs eligible to receive the COBRA subsidy anytime from April 1, 2021 through September 30, 2021. A termination for gross misconduct precludes the employee and all dependents from COBRA entitlement, and COBRA subsidies. Any employer that has a health plan subject to COBRA should be aware of these changes. What the COBRA Subsidy Means for Business. While the Subsidy Period runs until September 30, 2021, an individual’s right to the subsidy ends earlier in certain circumstances. The ARPA COBRA premium subsidy provisions require employers and insurers to provide "assistance eligible individuals" (AEIs) with a 100% subsidy for premiums otherwise owed for COBRA coverage during the period from April 1, 2021 to September 30, 2021 (Subsidy Period). The American Rescue Plan Act of 2021 (ARPA) was signed into law on March 11, 2021. COBRA Subsidy Eligibility. The American Rescue Plan Act of 2021 (ARPA) has some new rules related to the Consolidated Omnibus Budget Reconciliation Act (COBRA). The ARPA provides for a temporary 100% reduction in COBRA premiums for individuals who: (1) lose healthcare coverage due to an involuntary termination or a reduction in hours; (2) are eligible … Before sharing sensitive information, make sure you’re on a federal government site. 4/28/2021. The ARPA, among other things, makes significant changes to COBRA administration by providing for additional COBRA enrollment rights and a temporary 100% COBRA premium subsidy from April 1, 2021 to September 30, 2021. The American Rescue Plan Act of 2021 (ARPA) includes a federally-financed COBRA subsidy that is available for up to six months for eligible individuals. Persons eligible for the subsidy are called assistance eligible individuals or AEIs. Longstanding Coverage. The ARPA’s COBRA provisions permit employers who offer more than one level of health care coverage to allow anyone eligible for a COBRA subsidy to switch from a more expensive plan to a less expensive plan within 90 days of the employee’s receiving notice of … Assistance Eligible Individuals for periods of COBRA coverage that occur during the Subsidy Period. Under the COBRA ARPA subsidy rules, COBRA covered individuals are required to notify the employer if they become eligible for other group coverage or Medicare. ProBenefits COBRA Portal will be updated to allow employers the ability to identify and update the individual’s eligibility for the subsidy (AEIs). The following individuals who are or become qualified (employees plus affected spouses and dependent children) as the result o… For eligible COBRA enrollees, the Act offers the federal COBRA subsidy on the first day of the month following the legislation’s enactment, April 1, 2021, and ends on September 30, 2021. Getting in compliance with the ARPA COBRA program isn’t something your team can put off. On March 30, 2021, the availability of PPP loans was extended to May 31, 2021, or until allocated funds are exhausted. Under ARPA, COBRA participants must meet the below criteria in order to be an AEI: ARPA requires employers that sponsor group health plan coverage 1 to waive 100% of COBRA premiums for Assistance Eligible Individuals for periods of COBRA coverage that occur during the Subsidy Period. Premium Subsidy. Before face masks — or should I say no face masks — there was the American Rescue Plan Act of 2021.Among other things, the ARPA created a new COBRA premium subsidy — a temporary 100% reduction in the premium that individuals would have to pay when they elect COBRA … The American Rescue Plan Act (ARPA) provides a 100 percent COBRA subsidy to eligible individuals from April 1, 2021, through September 30, 2021 (Assistance Period). If qualified beneficiaries had COBRA coverage that lapsed or if they deferred their decision to elect but are still in the 12-month window of COBRA eligibility outlined in the COBRA Election and Premium Payments section above, they can elect COBRA coverage effective April 1, 2021 and be eligible for the subsidy. The COBRA subsidy will be fonted by the employer and later reimbursed by the federal government through payroll tax credits.

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