On April 7, 2021, the U.S. Department of Labor (DOL) released a link to its webpage dedicated to the COBRA premium assistance authorized under the American Rescue Plan Act, 2021 (ARPA), the third COVID-19 stimulus bill. As you may know, failure to provide accurate and timely COBRA notices come with hefty penalties, so compliance is imperative. For an AEI who already has COBRA coverage as of April 1, 2021, or an individual who is eligible for the special second election period, the notice must be provided by May 31, 2021. The Department of Labor recently published model notices plan sponsors and plan administrators may use to meet their disclosure obligations under the temporary COBRA subsidy added by the American Rescue Plan Act of 2021 effective April 1, 2021 (discussed here).At the same time, the DOL issued a series of Frequently Asked Questions about the temporary subsidy. The DOL has issued model notices and FAQs on the 100% COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARPA) (see our Checkpoint article).The subsidy is available from April 1, 2021 through September 30, 2021, to assistance eligible individuals (AEIs) who are eligible for and elect COBRA coverage—or comparable state continuation coverage—because of their … DOL has developed model notices for use by group health plans and health insurers that, pursuant to ARPA, must provide notices of the availability of premium reductions and additional election periods for COBRA continuation coverage. Failure to provide these notices is deemed a failure to meet the COBRA notice requirements. The webpage includes model notices, frequently asked questions, and related information.With the exception of the model notices, the guidance appears … The Department of Labor yesterday released FAQs, model notices and other guidance for employers and workers on COBRA premium assistance available under the American Rescue Plan Act.. 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. On April 7, 2021, the U.S. Department of Labor (DOL) released a link to its webpage dedicated to the COBRA premium assistance authorized under the American Rescue Plan Act, 2021 (ARPA), the third COVID-19 stimulus bill. The U.S. Department of Labor (DOL) will provide a model notice by April 10, 2021. This notice may be used for any individual who loses coverage due to a qualifying event for the period from April 1, 2021 to September 30, 2021, including due to a reduction in hours or involuntary termination of employment. The DOL is required to provide a model notice for this requirement by April 25. The webpage includes model notices, frequently asked questions, and related information. COBRA Penalties. The DOL’s Model Notice of Expiration of Premium Assistance can be found here. L. No. The DOL guidance contains 21 FAQs on topics such as eligibility, elections, notice requirements and duration of the subsidy. The Department of Labor (DOL) has issued model notices, FAQs and other materials for the COBRA premium assistance program that took effect on April 1 under the American Rescue Plan Act (ARPA) (Subtitle F of Pub. Recent DOL FAQs focus on what COBRA participants and beneficiaries need to know about premium assistance. The notice does not have to be provided to qualified beneficiaries whose subsidies end because their COBRA period ends. Employer Tax Credit The DOL published the following model notices: Model General Notice and COBRA Continuation Coverage Election Notice. The U.S. Department of Labor (DOL) has issued model notices and Frequently Asked Questions (FAQs) regarding the COBRA subsidy (see COBRA Premium Subsidy guidance) made available under the American Rescue Plan Act of 2021 (ARPA).. As explained in our previous advisory, ARPA provides a 100 percent COBRA subsidy to eligible individuals from April 1, 2021, through September 30, 2021. On Friday, February 26, the Department of Labor (DOL) published Disaster Relief Notice 2021-01, a follow up to the Joint Notice published May 4, 2020.The May notice required that health and retirement plans disregard a number of deadlines for individuals during the COVID-19 National Emergency, plus a 60-day period (the “Outbreak Period”) starting March 1, 2020. The law subsidizes the full premium for COBRA coverage between April 1 and Sept. 30, 2021, for eligible individuals who lose their group health coverage due to reduced work hours or involuntary termination … 117-2).Under the program, the federal government is subsidizing 100% of COBRA premiums for qualified beneficiaries who otherwise would lose employer health coverage …
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