If an employee declined COBRA coverage, or if the employee elected COBRA coverage and later discontinued it, the employee now has a second chance to elect coverage and receive the subsidy. (Photo: Shutterstock)
The American Rescue Plan Act of 2021 (ARPA), among other significant items, imposed new obligations for employers pursuant to the Consolidated Omnibus Reconciliation Act (COBRA). Specifically, ARPA requires employers to provide COBRA premium subsidies to certain employees from April 1, 2020, through Sept. 30, 2021. The requirement comes with complicating definitions, retroactivity provisions, and new forms, creating a temporary compliance issue for employers. On April 7, the U.S. Department of Labor issued model notices and "FAQ's" to assist with these compliance issues.
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