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of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021 (including a “Request for Treatment as an Assistance Eligible Individual” Form) The “summary” portion of this notice must be included with all three notices listed above: (i) the General Notice; (ii) the Notice in Connection with Extended Election Period; and (iii) the Model Alternative Notice. The “request” portion enables individuals to request premium assistance or to discontinue it. Next Steps and Takeaways With the model notices now available, employers are well-advised to begin the notificatio...

To embed, copy and paste the code into your website or blog: As discussed in a previous alert, The American Rescue Plan Act (ARPA) provides 100% subsidized premiums for health care continuation coverage under COBRA for eligible individuals and their dependents.   The subsidized premiums are available from April 1, 2021, through September 30, 2021 (the “Premium Assistance Period”), unless earlier terminated as discussed below. The Department of Labor (DOL) was charged with preparing model notices for employers, plan administrators, or insurance companies to send to eligible individuals, a...

To embed, copy and paste the code into your website or blog: On April 7, 2021, the U.S. Department of Labor (DOL) issued welcome guidance–including eagerly-anticipated model notices–to help employers and their COBRA administrators implement the temporary six-month (April 1 to September 30, 2021) COBRA premium subsidy provided under the American Rescue Plan Act of 2021 (“ARP”) with respect to certain individuals who have lost or who will lose employer-sponsored group health coverage due to a reduction in hours or involuntary termination of employment. DOL Guidance Packet. The DOL’s g...

To embed, copy and paste the code into your website or blog: As we discussed in a previous article, the American Rescue Plan Act of 2021 (ARP), provided premium assistance and an extended election period under COBRA and similar state laws for “assistance eligible individuals” (AEIs). Employers were required to provide certain notices to individuals regarding the premium assistance and extended election period, and the Department of Labor (DOL) was directed to issue model notices for such purposes. The DOL has now issued the model notices and has provided some further guidance on these pro...

As detailed in our March 17 Alert, the American Rescue Plan Act of 2021 (ARP) provides for a temporary 100 percent COBRA subsidy for eligible individuals whose qualifying event was an involuntary termination of employment or reduction in hours. The subsidy under the ARP is in effect from April 1, 2021, through September 30, 2021. The ARP makes the subsidy 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 through September 30, 2021: Is eligible for COBRA contin...