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Guidance Issued on Implementation of ARPA COBRA Premium Subsidy | Saul Ewing Arnstein & Lehr LLP


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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 t ....

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DOL Issues Guidance On COBRA Subsidy Provision Under The American Rescue Plan Act - Employment and HR


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On April 7, 2021, the Department of Labor (the DOL) issued
guidance (the Guidance) and model notices and forms for the
COBRA subsidy provision of the American Rescue Plan Act (the Act).
Although the Guidance, a series of frequently asked questions, is
directed to COBRA qualified beneficiaries, it provides useful
information to employers and service providers tasked with
administering the COBRA subsidy. Nonetheless, several important
questions remain unanswered including, most significantly, the
logistics of claiming a refundable federal tax credit to offset
employer-subsidized COBRA premium payments and the meaning of ....

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DOL Publishes Model COBRA Notices and Premium Assistance Guidance | Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.