The American Rescue Plan Act provides 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 qualified beneficiary must elect continuation coverage under Federal COBRA or state mini-COBRA requirements; have a qualifying event that is a reduction in hours or involuntary termination of employment; elect to be considered an assistance-eligible individual; and not be eligible for other group health coverage or Medicare.
While employers may be aware of the outreach to individuals that was required by May 31, 2021, employers must also be sure their ongoing COBRA notices include ARP language.
The notice that is sent when an individual experiences a qualifying event must be updated to provide information about the ARP premium subsidy. The U.S. Department of Labor released a model notice that is to be used for all qualifying beneficiaries with a qualifying event occurring from April 1, 2021 through September 30, 2021. A copy of this model notice may be accessed by clicking here.
The notice must now include a summary of the ARP provisions and a form for a qualified beneficiary to request to be treated as an assistance eligible individual.
If you use BAS’ Cobra Control Services for your COBRA information, you can be assured that BAS is using the most updated language for qualifying event letters. If you would like information about BAS’ COBRA and continuation of coverage services, contact your account manager or solutions@BASusa.com.