DOL Issues FAQs About American Rescue Plan's COBRA Subsidy

On April 7, 2021, the U.S. Department of Labor (DOL) issued answers to frequently asked questions (FAQs) about the American Rescue Plan Act’s (ARP) premium assistance for health insurance continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) and similar state mini-COBRA programs. The DOL’s FAQs are reprinted in this Compliance Bulletin.

The FAQs

The DOL’s new guidance on the COBRA subsidy consists of 21 FAQs, clarifying:

  • New plan notice requirements for the subsidy;
  • The applicability of the ARP election extension; and
  • That extended deadline relief under earlier federal guidance does not apply to the ARP’s COBRA notice and election time frames.

However, the FAQs explain that the prior COBRA deadline relief does apply to an individual’s eligibility to elect the COBRA subsidy based on an earlier qualifying event.

The ARP Subsidy

The ARP provides a 100% subsidy of COBRA premiums for eligible individuals who lost group health coverage due to a reduction in hours or involuntary termination of employment. The subsidy applies from April 1, 2021, through Sept. 30, 2021, and it is available to eligible qualified beneficiaries even if they earlier declined or dropped COBRA coverage.

If you would like to register for our ARPA Compliance webinar, which will cover 100% COBRA subsidies, click here.

If you would like to continue reading or download this 9-page article in its entirety, please fill out the form below. 

Combined HR Services provides practical human resources information and guidance based upon our experience in the industry and our experience with our clients.  Combined HR Services are not intended to be a substitute for professional advice.  Combined HR Services are designed to provide general information to human resources and/or business professionals regarding human resources situations commonly encountered.  Given the changing nature of federal, state and local legislation and the changing nature of court decisions, Combined HR Services cannot and will not guarantee that the information is completely current or accurate.  Combined HR Services do not include or constitute legal, business, international, regulatory, insurance, tax or financial advice.