DOL Issues Guidance On New COBRA Subsidy

You may remember that one type of COVID-19 aid provided by the American Rescue Plan Act (ARPA) was a subsidy for COBRA premiums. The ARPA provides a 100 percent premium subsidy – between April 1, 2021 and September 30, 2021 – for individuals whose reduction in hours or involuntary termination of employment makes them eligible for COBRA continuation coverage during this period. The ARPA also requires group health plans to provide notices to individuals losing health coverage to inform them about premium assistance that may be available to them.

The U.S. Department of Labor recently issued guidance on these new requirements. Specifically, the DOL published a Frequently Asked Questions to answer questions about this new aid as well as model notices for group health plans and employers to use to meet the ARPA’s notice requirements.

If you have questions about the new COBRA subsidy, please contact a KZA attorney. commend that you consult with counsel before issuing discipline for such conduct and consider training your supervisors on Section 7 protections. 

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