Q.- We operate a self-funded church plan. One of our former employees wants us to provide a premium subsidy for the continuation coverage we offer. Do we have to do that?
A.- The American Rescue Plan Act requires a COBRA premium subsidy be provided to certain eligible individuals who had a qualifying event of reduction of hours or involuntary termination of employment and receive continued health coverage under COBRA or state mini-COBRA rules.
If the continuation of coverage your plan offers is voluntary and not required under federal COBRA or any state mini-COBRA laws, you will not be required to offer the ARP premium subsidy.