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Work with your COBRA vendor/administrator to determine what solution will be available. Covered individuals who have not elected COBRA or who have terminated their COBRA coverage early have 60 days after receiving the COBRA subsidy notice to change their minds and elect COBRA coverage. We have previously written blog posts on the COBRA subsidy added by ARPA, the follow-up FAQs that were recently issued, and the new notice requirements for the COBRA subsidy. The model notices provide assistance in ensuring plan compliance with requirements. April 8, 2021. The American Rescue Plan Act of 2021 (“ARPA”) requires that employers provide 100% COBRA subsidies to certain assistance eligible individuals from April 1, 2021 through September 30, 2021. The model notices provide assistance in ensuring plan compliance with requirements. The Department of Labor (DOL) has issued a set of model notices and frequently asked questions to assist in the implementation of the COBRA subsidy provisions of the American Rescue Plan Act (ARPA). Employers must update their notices for future employee separations that occur prior to the sunset of the subsidy on September 30, 2021. 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 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 DOL must issue model expiration notices by April 25, 2021. MID-MAY 2021. The American Rescue Plan Act (ARPA), signed into law March 11, 2021, provides certain individuals 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 program (sometimes referred to as mini-COBRA). Model Notice in Connection with Extended Election Period: MS Word | PDF. General COBRA FAQs for Employers. April 8, 2021. summary, ARPA provides a tax-free 100% subsidy of COBRA premiums for assistance eligible individuals from April 1, 2021 through September 30, 2021 (the “Subsidy Period”). The DOL provided the following model notices as described more fully below: Notice: General Notice. ARP also requires group health plans to provide notices to individuals losing health coverage to inform them about premium assistance that … The subsidy applies from 4/1 – 9/30/21. On March 11, 2021, the American Rescue Plan Act (ARPA) was signed into law which provides a COBRA subsidy as outlined in our previous blog. DOL will provide model notices within 30 days of ARPA's enactment. The American Rescue Act of 2021 (ARPA) is the latest federal law addressing the economic impact of the COVID-19 pandemic. By mid-May these new model notices will be ready for customization and release 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. Content: The notice must describe the availability of the ARPA COBRA subsidy (along with specific content requirements). Otherwise, you will need to provide these notices. The ARPA required the DOL to issue model notices that employers could use to satisfy their COBRA subsidy notice obligations under the ARPA. 2021 (ARPA). Even though Medicare (or group health plan) eligibility makes someone ineligible for the subsidy, the Model ARPA General Notice and Election Notice and Extended Election Period Notice should be sent to all applicable employees identified above to satisfy COBRA notification responsibilities. The ARPA, among other things, makes significant changes to COBRA administration by providing for additional COBRA enrollment rights and a temporary 100% COBRA premium subsidy from April 1, 2021 to September 30, 2021. Employers can visit the DOL’s new COBRA Premium Subsidy page, which contains the model notices and a FAQ page with more details on the ARPA’s COBRA provisions. The notice must be written in clear and understandable language, and it must inform recipients of the availability of ARPA premium assistance and the option under the ARPA to enroll in different coverage (if the employer permits the option). The American Rescue Plan Act COBRA subsidy: The ARPA directs DOL to issue model notices that will satisfy the requirements for COBRA subsidy notification by May 1. Plans may use the DOL model notices to meet their notice obligations under the COBRA subsidy provisions of the ARPA. The model notices issued by the DOL should be used by employers to satisfy the COBRA notification requirements of ARPA and provided to "assistance eligible individuals" before May 31, 2021. 2021 (ARPA). As we previously reported, on March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (“ARPA”) into law, which includes a COBRA premium assistance program.Pursuant to ARPA, the Department of Labor (DOL) was instructed to issue model notices regarding the six-month subsidy period, the extended election period, the alternative coverage option, … The DOL provided the following model notices … Model notices. In addition to the notices described above regarding the availability of COBRA and the subsidy, ARPA requires a special subsidy termination notice in most cases. If you use isolved Benefit Services for COBRA administration, isolved Benefit Services will notify assistance eligible individuals on the employer’s behalf. Background. More guidance from the IRS is expected regarding the mechanics of applying for and Summary of ARPA Provisions and Request for AEI Treatment Form, allows AEIs to elect COBRA in the normal course and request the subsidy by using the form to request AEI status. Model notice about extended election period (for subsidy eligible people with a COBRA election in effect on April 1, as well as people who may be eligible for the subsidy if As a reminder, ARPA provides a 100% subsidy for employer-sponsored group health insurance continued under COBRA and similar state continuation of coverage programs for eligible individuals, who lose (or lost) health coverage due to a reduction in hours or involuntary termination of employment. This model notice must be used to notify AEIs that their premium assistance is set to expire. On March 11, 2021, President Biden signed into law the American Rescue Plan Act (“ARPA”), which requires plan sponsors to provide free COBRA coverage from April 1, 2021, through September 30, 2021, to individuals who lose coverage due to an involuntary termination of employment or reduction of hours. By Joshua M. Osborne and Alexandra A. Ifrah. As part of the American Rescue Plan Act (ARPA) of 2021, plan sponsors of group health plans will be required to offer a COBRA premium subsidy for coverage between April 1 and September 30, 2021. By Joy M. Napier-Joyce on April 7, 2021. A summary of the ARPA COBRA subsidy requirements is provided below. The Department of Labor (DOL) Employee Benefits Security Administration (EBSA) has created a new … summary, ARPA provides a tax-free 100% subsidy of COBRA premiums for assistance eligible individuals from April 1, 2021 through September 30, 2021 (the “Subsidy Period”). What model notices/forms did DOL release? PBA will provide you with updated guidance when this information becomes available from the Department of Labor. Employers should expect to use the normal COBRA model notices for all qualifying events occurring after the COBRA subsidy program expires on Sept 30. Below is an overview of what we deem the most relevant pieces of the guidance in more detail. ARPA requires employers to notify qualified beneficiaries regarding the availability of this COBRA subsidy and their related rights. Employers must also send out notice between 15 and 45 days prior to the date when subsidies expire. The American Rescue Plan Act of 2021 (“ARPA”) requires that employers provide 100% COBRA subsidies to certain assistance eligible individuals from April 1, 2021 through September 30, 2021. Sponsors of group health plans have new responsibilities following the passage of the American Rescue Plan Act (“ARPA”) on March 11, 2021. Alternative Notice – available here. The Department of Labor will be issuing model notices by April 10, 2021. Action Steps: Identify COBRA qualified beneficiaries who are assistance eligible individuals; The ARPA required the DOL to create three model notices (general, election and termination of the subsidy). This notice is the only notice required for the purposes of informing beneficiaries of their continuation coverage rights and ARP information during the subsidy period. If you use isolved Benefit Services for COBRA administration, isolved Benefit Services will notify assistance eligible individuals on the employer’s behalf. In addition to the Model Notices, the DOL also issued a Summary of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021, which contains information on the subsidy … Employers sponsoring group health plans that are subject to COBRA now have access to model notices and guidance from the Department of Labor (“DOL”) related to the full COBRA premium subsidy provisions in the American Rescue Plan Act of 2021 (“ARPA”). Most aspects of the law do not directly affect the employer’s HR/Benefits function, but ARPA does include an optional extension of sick and family leave (see our summary) and the establishment of a COBRA subsidy.. See the SHRM Online article DOL Issues COBRA Subsidy Guidance and Model Notices. Failure to issue these notices will be treated as a failure of COBRA’s notice requirements. The DOL subsequently announced in the Federal Register the availability of these model notices. Model ARPA COBRA Notices Have Arrived! ARPA requires employers to notify qualified beneficiaries regarding the availability of this COBRA subsidy and their related rights. Under this new law, the federal government is covering 100% of the cost of qualifying COBRA coverage from April 1st, 2021 through September 30, 2021. This article takes a closer look at the COBRA subsidy. We previously discussed the ARPA COBRA subsidies in our prior blog . Model Alternative Notice of ARP Continuation Coverage Election Notice (For use by insured coverage subject to tate continuation requirements s between April 1, 2021 and September 30, 2021.) New Model Notices . 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. The American Rescue Plan Act of 2021 (ARPA) COBRA premium subsidy provisions require assistance‑eligible individuals (AEI) to be treated as having fully paid the premium owed for COBRA continuation coverage (COBRA Subsidy) during the period from April 1, 2021 through September 30, 2021 (Subsidy Period). The Alternative Notice is purposed for those Plans that are subject to state continuation requirements (aka mini Cobra) from April 1, 2021 through September 30, 2021. The ARPA provides 100% subsidy for employer-sponsored group health insurance continued under COBRA along with similar state continuation of coverage programs for those who are eligible. Tax Credit. How to Send: Should be sent with the Summary of the COBRA Subsidy Provisions (which contains the subsidy request form) Model Notice: ARPA General Notice and COBRA Continuation Coverage Election Notice. Employers may use the DOL model notices to meet their notice obligations under the ARPA’s COBRA subsidy provisions. The American Rescue Plan Act of 2021 (“ARPA”) signed by President Biden. The ARP provides a 100 percent premium subsidy – between April 1, 2021 and Sept. 30, 2021 – for individuals whose reduction in hours or involuntary termination of employment makes them eligible for COBRA continuation coverage during this period. These individuals must be given a new 60-day COBRA election period, and group health plans will be required not only to provide updated general COBRA notices, but also to provide updated election notices with information about the subsidy. ARPA requires the Department of Labor to release Model Notices and further guidance relating to these subsidy provisions. For assistance-eligible individuals (AEIs), ARPA offers 100% subsidies of COBRA premiums for coverage periods from April 1, 2021 through Sept. 30, 2021. Hodgson Russ Employee Benefits Alert. 2021 (ARPA). 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. By Beth Alcalde and Amber N. Roberts. General Notice Plan administrators must provide notification of COBRA benefits under ARPA. April 8, 2021. The guidance includes Frequently Asked Questions (FAQs) and various Model Notices and election forms implementing the … The American Rescue Plan Act of 2021 ARPA is the latest federal COVID-19 relief bill. Department of Labor Releases COBRA Subsidy Model Notices and Frequently Asked Questions As previously reported1, the American Rescue Plan Act of 2021 (ARPA) introduced a 100 percent federal subsidy of COBRA continuation coverage premiums for periods of coverage between April These answers take into account the guidance in Notice 2021-31 issued … March 11, 2021. The new 100 percent premium subsidy applies to individuals eligible for Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage due to either a reduction in hours or an involuntary termination of employment, and it applies for the period from April 1, 2021, to September 30, 2021. For more details on the COBRA provisions of ARPA see: American Rescue Plan Act of 2021 and COBRA Subsidies. April 10, 2021. The subsidy can end before September 30, 2021 if COBRA or state continuation expires before then because the availability of the subsidy does NOT extend COBRA beyond the original maximum coverage period. DOL model notices to meet their notice obligations under the COBRA subsidy provisions of the ARPA. The FAQs and model notices can be found on the DOL website, dedicated to providing guidance on the ARPA COBRA Subsidy. IRS Notice 2021-31* covers a range of topics related to the COBRA premium assistance provisions of ARPA and additional COBRA enrollment opportunities afforded to certain Assistance Eligible Individuals (AEIs) during the ARPA subsidy period beginning April 1, 2021 through September 30, 2021. On April 7, 2021, the U.S. Department of Labor (DOL) issued eagerly anticipated guidance on administering COBRA subsidies under the American Rescue Plan Act of 2021 (ARPA). ARPA includes new COBRA continuation coverage election, notice, and subsidy … 1. More guidance from the IRS is expected regarding the mechanics of applying for and IRS Notice 2021-31* covers a range of topics related to the COBRA premium assistance provisions of ARPA and additional COBRA enrollment opportunities afforded to certain Assistance Eligible Individuals (AEIs) during the ARPA subsidy period beginning April 1, 2021 through September 30, 2021. DOL Releases Model Notices for ARPA COBRA Premium Subsidy. By Lauren Bikoff, MLS. Model Notices. ARPA COBRA Subsidy Model Notices and FAQs Issued. April 10, 2021. Department of Labor is due to respond with model notices and additional guidance. Under ARPA, a 100% COBRA premium subsidy and additional COBRA enrollment rights are available to certain assistance eligible individuals (AEIs) during the period beginning on April 1, 2021, and ending on September 30, 2021. ARPA requires that the Expiration Notice be sent to Assistance Eligible Individuals whose COBRA subsidy is either terminating (1) prior to September 30, 2021, because the normal COBRA …

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