Importantly, small employers are not required to "look back" to past terminations or reductions of hours the way employers with 20 or more employees are required to do.
Benefits brokers who consult with plan administrators of employer-sponsored group health plans, will need to ready clients for the multiple phases that will follow receipt of qualified beneficiaries' American Rescue Plan Act ("ARPA") subsidy elections, which will start rolling in during the next month. Not since 2009 has a plan administrator had such an active role to plan in the administration of COBRA.
Background
The ARPA, included the 100% federal subsidy for COBRA and continuation coverage under state mini-COBRA laws for the period of April 1, 2021 through September 30, 2021. (For the sake of clarity, we will refer only to federal COBRA, although some of the rules also apply to state continuation.) As is often the case with legislative language, the release of ARPA led to a wave of questions on how the subsidy works. To address these questions, the Department of Labor ("DOL") released an FAQ and model notices. The Treasury Department and IRS released 86 FAQs in Notice 2021-31.
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