On May 18, 2021, the IRS released Notice 2021-31 (the “Notice”) providing guidance on the temporary 100% COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”), summarized generally here. The Notice...more
One important question that arises when determining whether an individual is eligible for the COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”) is whether the employee has experienced an involuntary...more
In an earlier post we reviewed the end dates for the ARP COBRA premium subsidy provided by the American Rescue Plan Act of 2021 (“ARP”), and addressed the required expiration notice. This post revisits the topic in light of...more
Due to tight timelines and an initial sprint to issue the special extended COBRA election period notices by the May 31st deadline, plan administrators may not have focused on the other COBRA-related notice requirements under...more
4/22/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Premium Subsidies ,
Relief Measures ,
Special Election
The American Rescue Plan (“ARP”) offers a special 60-day election period for certain individuals who previously declined or discontinued COBRA coverage (“Assistance Eligible Individuals” or “AEIs,” as defined in ARP). These...more
4/22/2021
/ American Rescue Plan Act of 2021 ,
Benefit Plan Sponsors ,
COBRA ,
Coronavirus/COVID-19 ,
Corporate Counsel ,
Department of Labor (DOL) ,
Employee Benefits ,
Employer Group Health Plans ,
Premium Subsidies ,
Relief Measures ,
Special Election
As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible...more