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On May 18, 2021, the IRS issued the long- awaited guidance on the COBRA subsidy and premium assistance credit available under the American Rescue Plan Act of 2021 through eighty-six questions and answers. The Notice addresses eligibility, reduction in hours, involuntary termination of employment, coverage eligible for premium assistance, beginning and end of the premium assistance period, extended elections, calculation of the premium assistance credit and other common questions.
The bad news is the plethora of questions. The good news is that an employer may rely upon an employee’s attestation in determining if an individual is an Assistance Eligible Individual, unless the employer has actual knowledge that the individual’s attestation is incorrect. The employer should keep the employee’s attestation as documentation that the individual was eligible for the premium assistance.
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The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the American Rescue Plan Act.
Notice 2021-31 (the Notice) is lengthy, at more than 40 pages with 86 questions and answers. Despite its length, much of the guidance is not surprising and is a carryover of previous Internal Revenue Service (IRS) guidance related to the COBRA subsidy under the American Recovery and Reinvestment Act of 2009. The Notice comes as plan sponsors and COBRA administrators are gearing up to issue required notices to subsidy eligible individuals under the American Rescue Plan Act (ARPA) (known as assistance eligible individuals).
COBRA Subsidy Key Provision Clarification in IRS Notice natlawreview.com - get the latest breaking news, showbiz & celebrity photos, sport news & rumours, viral videos and top stories from natlawreview.com Daily Mail and Mail on Sunday newspapers.
Wednesday, April 28, 2021
The COBRA subsidy period (April 1, 2021 – September 30, 2021) has begun and with a number of issues still outstanding, employers have no time to lose when it comes to preparing to administer the COBRA subsidy required by the American Rescue Plan Act (ARPA) enacted on March 11, 2021. While we have received limited guidance from the U.S. Department of Labor (DOL), we still expect and await additional guidance from the DOL and the Internal Revenue Service (IRS). Below are considerations for employers to begin thinking about now, including upcoming notice obligations.
Determine whether the employer’s plan is covered under the COBRA subsidy rules. All group health plans subject to federal COBRA and mini-state COBRA (e.g., this commonly includes fully-insured plans) are subject to the COBRA subsidy rules.
ARP COBRA Subsidy Special Election Opportunity: Who Gets a Second Bite at the Apple, and How Do They Take It? | Proskauer - Employee Benefits & Executive Compensation Blog 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.