Q: Does the American Rescue Plan Act of 2021 (ARPA) impact group health plans?
A: Yes, ARPA makes temporary but significant changes to Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) coverage. These changes, at a high level, include:
A 100% COBRA subsidy for the period of April 1 through Sept. 30, 2021.
A second “bite at the apple” for COBRA qualified beneficiaries who previously did not elect COBRA or who previously elected COBRA and dropped the coverage.
The opportunity to offer COBRA covered individuals the chance to change their elected option to a cheaper option.
Q: Who qualifies for the 100% subsidy?
A: Only “assistance eligible individuals” (AEIs) qualify for a subsidy. An AEI is someone who, in the time period between April 1 and Sept. 30, 2021, is eligible for COBRA coverage due to an involuntary termination (other than for gross misconduct) or a reduction in hours and elects such coverage. An AEI no longer is eligible for a subsidy upon the earl
Analysis
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Speaker Nancy Pelosi and Senator Chuck Schumer, the majority leader, signed the stimulus bill this week while surrounded by Democratic members of Congress.Credit.Stefani Reynolds for The New York Times
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On March 11, 2021, President Biden signed into law the “American Rescue Plan Act” (“ARPA”) (HR 1319). While ARPA addresses many different areas, employers will need to act promptly with.
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