COBRA Subsidy Provisions of the American Rescue Plan Act

The American Rescue Plan Act (ARPA), signed into law March 11, 2021, provides a 100% subsidy of premiums for employer-sponsored group health insurance continued under the Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) and similar state continuation of coverage (mini-COBRA) programs.

ARPA subsidies cover the full cost of COBRA or mini-COBRA premiums from April 1, 2021, through Sept. 30, 2021, for employees (and their qualifying family members), if the employee lost or loses group health insurance due to an involuntary job loss or reduction in work hours. The subsidy applies to people who are still within their original COBRA or mini-COBRA coverage period, for the length of that coverage period, even if they declined or dropped COBRA or mini-COBRA coverage earlier.

The subsidy does not apply to:

Individuals whose job loss was voluntary or the result of gross misconduct; or
Individuals who are eligible for another group health plan or Medicare.

The subsidies are funded through a payroll tax credit. Employers are required to provide new notices about the subsidy to employees. The U.S. Department of Labor (DOL) will issue model notices for this purpose.

Action Steps

Employers should familiarize themselves with the provisions of the ARPA and watch for agency guidance on its implementation.

Highlights

Eligible Individuals
The subsidy is generally available to people who elected COBRA, become eligible for COBRA, or declined or discontinued COBRA and are still within their original COBRA coverage period.

Funding
The subsidy is funded by a refundable, advanceable credit against payroll taxes taken by employers or carriers.

Option to Switch Coverage
The ARPA allows covered individuals to switch to similarly priced health coverage, if the employer allows it.

Important Dates

April 1, 2021
ARPA 100% subsidy begins to cover COBRA premiums.

Sept. 30, 2021
ARPA subsidy provision for COBRA premiums expires.

For more information on the American Rescue Plan Act, read this HR Compliance Bulletin and contact HANYS Benefit Services by email or by calling (800) 388-1963.

This Compliance Bulletin is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2021 Zywave, Inc. All rights reserved.

SECURE 2.0 Discussion Series: Session Two

The retirement industry has been buzzing since the SECURE 2.0 Act was signed into law last December. This new, comprehensive legislation has sparked a lot of discussion. As with any major reform, it will take time for the industry to fully adapt and understand all its implications. Following our April 11 webinar on the first three months of the industry’s response, our team reconvened to discuss some of what we have heard from our client and vendor partners and to respond to some of the great questions we heard from attendees. Panel participants included the following HBS team members: Noah Buck, Christina Bauer-Dobias, Sean Bayne, Vincent Bocchinfuso and Kathleen Coonan. The Discussion SB – Throughout the webinar, I wanted to stress two things: 1) confusion about where to start and what is expected from plan sponsors is normal; and 2) even more than three months in, this is a developing situation and people should expect changes as time goes on. With those in mind, engagement through

SECURE 2.0 Discussion Series: Session One

SECURE 2.0 provisions: What we know and what’s still up in the air The SECURE 2.0 Act, signed into law in late December 2022, has factored heavily in retirement industry discourse since the final legislation was published. As with any legislation of this depth and breadth, there’s a lot to digest and the industry takes time to adjust. Our team of experienced advisors recently met to discuss some of the more nuanced provisions of the legislation, such as changes to Roth contributions, and what they could mean for plan sponsors. Panel participants included the following HBS team members: Noah Buck, Christina Bauer-Dobias, Sean Bayne, Vincent Bocchinfuso and Kathleen Coonan. Highlights of our panel’s conversation below should serve to help guide plan sponsor thinking. On Roth employer contributions NB – In addition to deferring pre-tax or Roth, plan sponsors can now allow employer contributions to be classified as Roth, is that right? VB – Correct. This is immediately available to plan s

What you should know about biosimilars

Rapidly increasing healthcare costs will likely continue to impact employers for the foreseeable future. As a result, many employers are considering strategies to manage these costs, including rising prescription drug costs. The introduction of biosimilar drugs as an alternative to biologics may bring value to healthcare by offering cost savings and increasing employee access to necessary medications. While biosimilars can potentially combat rising prescription drug costs, employers will need to learn more about them before considering how their health plans can accommodate these newer drugs. This article explores biosimilar drugs and ways employers can promote or manage their use. What are biosimilars? The European Medicines Agency defines a biosimilar as “a biological medicine highly similar to another already approved biological medicine.” It is produced from living organisms — humans, animals or microorganisms, meaning they aren’t created from synthesized chemicals. They are also

HANYS Benefit Services

Search This Blog