DOL Issues Model Notices, FAQs for COBRA Subsidy Under ARPA
April 7, 2021
Plans May Use Model Notices for New COBRA Notice Obligations
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. The subsidy applies from April 1 through September 30, 2021. The notices and FAQs appear on a new DOL web page dedicated to the ARPA COBRA subsidy.
The new model notices released by the DOL are the following:
- Model General Notice and COBRA Continuation Coverage Election Notice
- Model Notice in Connection with Extended Election Period
- Model Alternative Notice
- Model Notice of Expiration of Premium Assistance
- Summary of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021
The DOL guidance contains 21 FAQs on topics such as eligibility, elections, notice requirements and duration of the subsidy. Notably, the FAQs state that prior federal COVID-19-related relief for plan deadlines does not apply to notice or election periods set forth in the ARPA provisions about the COBRA subsidy. However, an individual may elect COBRA from an earlier qualifying event if the individual is eligible to make that election, including under the extended time frames provided under the prior deadline relief.
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