The 100% premium subsidy will be reimbursed to employers through their quarterly payroll tax returns. The DOL has issued model notices and FAQs on the 100% COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARPA) (see our Checkpoint article).The subsidy is available from April 1, 2021 through September 30, 2021, to assistance eligible individuals (AEIs) who are eligible for and elect COBRA coverage—or comparable state continuation coverage—because of their … For all qualified beneficiaries who become eligible for COBRA between April 1, 2021, and September 30, 2021, the ARPA requires plan administrators to provide notice to these individuals that COBRA premium assistance is available, and they have the option to enroll in different coverage if the employer permits it. The Department of Labor (DOL) has released model notices that employers should use to alert their former employees about the COBRA subsidy for 2021. A COBRA subsidy program was enacted in March 2021 under the American Rescue Plan Act (ARPA), as described in Holland & Knight's previous alert (see "COBRA Premium Subsidy Under the American Rescue Plan Act," March 30, 2021).On April 7, 2021, the U.S. Department of Labor (DOL) released guidance and model notices on an information webpageinformation On April 7, 2021, the U.S. Department of Labor (DOL) issued FAQs and model notices for the COBRA premium assistance provisions of the American Rescue Plan Act (ARPA).The ARPA provides a 100% subsidy for employer-sponsored group health insurance continued under COBRA and similar state continuation of coverage programs for eligible individuals. On April 7, 2021, the U.S. Department of Labor (DOL) released various documents pertaining to the COBRA premium assistance provisions contained in the American Rescue Plan Act (ARPA), including Frequently Asked Questions (FAQs) and Model Notices and election forms, as well as the launch of a page dedicated to COBRA Premium Subsidy guidance on its website. During the COBRA subsidy period (April 1, 2021 through September 30, 2021), all qualified beneficiaries who become entitled to elect COBRA coverage must be provided a COBRA election notice that includes information about the availability of the premium subsidy—regardless of whether the qualified beneficiary is actually eligible for the subsidy. On April 7, 2021, the U.S. Department of Labor issued FAQs and five model notices for the COBRA premium subsidy provided by the American Rescue Plan Act (ARPA), which we discussed in our March 16, 2021 E-lert. The Model ARPA General Notice and COBRA Continuation Coverage Election Notice, which should be used for all qualifying events occurring from April 1, 2021 to September 30, 2021, alerts the recipient to the availability of the ARPA COBRA premium subsidy, and includes a COBRA … The ARPA provides a 100% subsidy for COBRA continuation coverage premiums from April 1, 2021 … A New COBRA Subsidy Until September 30, 2021 for Involuntary Terminations. A Model COBRA Notice with Extended Election Periods – to be provided to individuals who may be eligible for the COBRA subsidy where the qualifying event (involuntary termination of employment or reduction in hours) occurred before April 1, 2021. DOL Issues Model COBRA Subsidy Notices and Initial Guidance on COBRA Subsidy Relief under the American Rescue Plan Act of 2021 Karen Gelula , Monica Novak Faegre Drinker Biddle & … From April 1, 2021 extending to September 30, 2021, any employers with plans subject to COBRA continuation will need to offer a 100% subsidy for up to a six-month period. The recently enacted American Rescue Plan Act of 2021 (ARP), signed into law on March 11, 2021, includes a 100% COBRA subsidy for certain individuals for … If you have COBRA-eligible participants (other than those eligible as a result of a voluntary termination) on April 1, 2021, the new subsidy will apply to their coverage cost until their COBRA eligibility ends or October 1, 2021, whichever comes first. Notice Requirements. The American Rescue Plan Act (ARPA), signed by President Joe Biden on March 11, 2021, included a COBRA Subsidy covering 100% of COBRA premiums for “Assistance Eligible Individuals” during the period of April 1, 2021 through September 30, 2021.
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