The IRS issued Notice 2021-46 providing additional direction on the COBRA premium subsidy required under the American Rescue Plan Act (ARPA). This guidance provides details on items not addressed previously.
ARPA requires a 100% COBRA premium subsidy for certain individuals entitled to COBRA due to reduction of hours or involuntary termination of employment. To be eligible for the subsidy, the COBRA qualified beneficiary must have a qualifying event that is a reduction in hours or involuntary termination of employment, elect COBRA, elect to be considered an assistance-eligible individual, and not be eligible for other group health coverage or Medicare. Refer to our prior article which may be found here.
Notice 2021-46 makes the following clarifications:
A copy of the new notice may be accessed by clicking here.