On April 7th, the Department of Labor (DOL) issued model notices, FAQs, and other materials related to the COBRA premium assistance program that took effect on April 1st as a result of the American Rescue Plan Act (ARPA). All DOL materials are available on a dedicated website. Employers need to work with their COBRA service providers to provide the model notices as soon as possible.
The subsidy – which pays 100% of COBRA premiums -- is available from April 1st to September 30th to assistance eligible individuals (AEIs). An AEI is a qualified beneficiary who lost group health plan coverage (other than health FSA benefits) due to reduction of hours or involuntary termination of employment and whose original maximum COBRA coverage period overlaps the COBRA subsidy period by at least one month.
The FAQs clarify some issues, including:
Four model notices were included:
A detailed GRIST analysis will soon be available on Mercer’s Law & Policy Group – Our Thinking page.