On May 18, 2021, IRS issued Notice 2021-31 regarding COBRA premium subsidy provisions of ARPA. The IRS has now issued additional FAQs in the Notice Below is a summary of the provisions of the Notice most relevant to employers and plan sponsors.
On May 18, 2021, the Internal Revenue Service (IRS) issued much-anticipated Notice 2021-31 (the Notice) regarding the Consolidated Omnibus Budget Reconciliation Act (COBRA) premium.
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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”). An AEI is an employee who has experienced a “qualifying event,” which is either an “involuntary termination” or a “reduction of hours,” and who is, or could have been, eligible for COBRA coverage during the Subsidy Period. Generally, the qualifying event must occur during the Subsidy Period; however, former employees who experienced qualifying events before the Subsidy Period are also eligible under ARPA for an extended COBRA election period.
Seyfarth Synopsis:
The IRS has announced the adjustments to key limits for certain health and welfare benefit programs, including HDHP deductibles, HSA and FSA contributions, and other fringe benefit options for 2021.
The IRS issued new limits on health and fringe benefit options under Rev. Proc. 2020-32, Rev. Proc. 2020-45, and Notice 2020-84, which announce the 2021 limits for certain benefit programs, including dollar limits for contributions to health savings plans (“HSAs”) under high deductible health plans (“HDHPs”), flexible spending accounts (“FSAs”) under Section 125 cafeteria plans, qualified transport fringe benefit programs, Qualified Small Employer Health Reimbursement Accounts (“QSEHRAs”), and the new PCORI fee.