COBRA
On May 18, 2021, the Internal Revenue Service (IRS) issued Notice 2021-31 with additional guidance pertaining to the COBRA subsidies authorized under the American Rescue Plan Act of 2021 (“ARPA”). The guidance is broken up into various sections and consists of 86 different frequently asked questions (FAQs). Some details summarizing the guidance has been provided below.
The U.S. Department of Health and Human Services (HHS) recently finalized its Notice of Benefit and Payment Parameters which is also summarized in this Fact Sheet. These regulations are issued each year and make updates and changes to various provisions of the Affordable Care Act (ACA).
The Department of Labor (DOL) issued an FAQ on April 7, 2021 relative to the application of COBRA subsidies authorized under the American Rescue Plan Act of 2021 (ARPA). The information below summarizes the content of the FAQ.
Model Notices
The DOL has provided the following model notices:
On March 11, 2021, President Joseph Biden signed into law the American Rescue Plan Act (ARPA). ARPA is the third stimulus package signed into law in response to the COVID-19 pandemic. Under ARPA, two significant provisions were included that will help more Americans obtain and pay for health insurance coverage.
UPDATE: We have since received additional guidance from the Department of Labor, which clarifies that the COBRA extension end date is specific to each individual.
Joseph Biden was sworn in as the 46th President of the United States less than one week ago, and he has already introduced his ideas for a third economic stimulus package.
The Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) requires employers with 20 or more employees to offer continuation coverage under a group health plan for periods of 18, 29 or 36 months depending on the qualifying event.
Many employee benefit laws only apply to employers who have a certain number of employees. The challenging part is that each law has its own definition and rules on how to count the number of employees when determining if a law applies to an employer. Here are some key examples:
The U.S. Department of Labor (DOL) has issued guidance that will impact COBRA procedures, special enrollment periods, and claims procedures. The guidance will extend the length of certain time periods applicable to group health plans, disability plans and other welfare plans regulated by the ERISA law. Plan participants and beneficiaries will have additional time to do the following:
COBRA has been an administrative challenge for employers dating back to 1986 when it first became effective. On the surface, it’s easy to comprehend COBRA and its purpose, but behind the scenes, an employer has a lot of obligations it must account for to ensure compliance with the law. Take this scenario for example:
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