Cobra Control Services, LLC (“CCS”) has been communicating with clients about a new COBRA premium subsidy under the American Rescue Plan Act (“ARPA”) that may be available to former employees.
Organizations who have not responded to CCS’ request for information must do so immediately in order for CCS to help with COBRA compliance obligations. Action is required no later than May 21, 2021.
Please access MyEnroll360 and identify your COBRA population’s qualifying events as a voluntary or involuntary termination of employment. To do this, log into MyEnroll.com and under Quick Links (section on right side of page with large blue button), click “COBRA Qualifying Event Reason Manager” to make the selections.
If you do not identify your COBRA population’s qualifying events in MyEnroll360 as voluntary or involuntary termination of employment by May 21, 2021, CCS will take that as your direction that each person’s qualifying event reason was voluntary and the individual is not eligible for the ARPA COBRA premium subsidy and/or a new COBRA election period. That means CCS will not send notice to the individual(s) and your organization may fail to comply with the May 31, 2021 COBRA notice distribution due date. Not sending the required APRA COBRA premium subsidy notice to someone who is eligible could subject a company to an excise tax under the Internal Revenue Code. This tax could be as much as $100 per qualified beneficiary, up to $200 per family, for each day the organization is in violation of the COBRA rules for not sending the required notice. CCS will not send the ARPA COBRA premium subsidy notice on an organization’s behalf unless the COBRA Qualifying Event Reason Manager module in MyEnroll360 is completed by May 21, 2021.
If you have questions about the COBRA premium subsidy or making a qualifying event designation, contact your account manager or info@cobracontrol.com.
