COBRA subsidy strikes again with IRS guidance in Notice 2021-31 | Eversheds Sutherland (US) LLP jdsupra.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from jdsupra.com Daily Mail and Mail on Sunday newspapers.
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The Affordable Care Act requires employers who sponsor self-funded health plans (including certain HRAs) to pay the Patient-Centered Outcomes Research Institute (PCORI) fee to the IRS. The fee is based on the average number of covered lives under the plan and must be reported once a year on the second quarter IRS Form 720 and paid annually by July 31st. For the 2021 payment cycle, the due date has been extended to August 2nd since July 31st falls on a Saturday. Although Form 720 is a quarterly form, for PCORI, Form 720 is filed once annually.
The PCORI fee was originally scheduled to expire in late 2019, but federal legislation passed in December 2019 extended the PCORI fee obligation for all plan years ending before October 1, 2029. There was no change to the type of plan subject to the PCORI fee. The government simply extended the original sunset date from 2019 to 2029.
New federal law (Section 9501 of the American Rescue Plan Act of 2021 – ARP Act, PL 117-2) provides a temporary, full subsidy of some premiums that individuals would have to pay for.
Jason Flohrs: Public option isn’t the answer for Minnesotans
The pandemic has highlighted the problems with a bloated, broken and bureaucratic health care system – why double down on that failed approach?
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Jason Flohrs | ×
Jason Flohrs
Minnesota lawmakers are attempting to radically upend our health system under the assumption that “more government” is the best way to ensure access and affordability.
In reality, it will do the opposite.
Included in the health omnibus bill is the so-called public option, the next step on the state’s march toward “Medicare for All.” This allows the state to tax and regulate private insurance companies while at the same time directly competing with them. With government authorized to legally undercut their prices and subsidize their competition, why would these companies stick around? They’ll start withdrawing from Minnesota, leaving us stranded with only one option – the “public” one.
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Group health continuation coverage under the Consolidated Omnibus Reconciliation Act of 1985 (“COBRA”) permits certain group health coverage to be continued by participants and beneficiaries (“qualified beneficiaries”) when coverage is lost due to certain “qualified events,” such as termination of employment or a reduction of hours.
Under Section 9501 of the American Rescue Plan Act of 2021 (“ARPA”), an “assistance eligible individual” (“AEI”) is not required to pay the cost of COBRA coverage (“COBRA Subsidy”) for the period beginning April 1, 2021 through September 30, 2021 (“Subsidy Period”). The Employee Benefits Security Administration has issued guidance, including Frequently Asked Questions (“FAQs”) and Model Notices related to the COBRA Subsidy. Employers offering COBRA are required to provide the COBRA Subsidy to any AEI, which they then can recoup through a payroll tax credit