As detailed in Lake Effect's prior blog post, the American Rescue Plan Act of 2021 (ARPA) includes provisions requiring employers to temporarily subsidize the cost of COBRA continuation coverage for certain “Assistance Eligible Employees” from April 1, 2021 through September 30, 2021. Employers or plan issuers must pay premiums on behalf of such individuals and will be reimbursed through a COBRA premium assistance tax credit.
Pursuant to ARPA’s specific requirements, employers and plan issuers are also required to provide Assistance Eligible Individuals with a Notice of Expiration of Premium Assistance 15-45 days before the recipient’s premium assistance expires. For individuals still receiving the premium subsidy, this means that the expiration notice must be provided no later than September 15, 2021. Failure to meet this deadline may result in penalties. Employers should ensure that these notices are sent out in timely manner by internal HR staff, health plan issuers, or COBRA administrators.
Lake Effect is here to answer your questions about COBRA compliance, as well as other state and federal employment law issues. We continue to monitor important legal and HR developments, as well as COVID-related updates from federal, state, and local authorities. Please keep watching our blogs and emails for these important updates, as well as discussions of how compliance meets culture. To dive into these issues, contact us at firstname.lastname@example.org or 1-844-333-5253.