COVID-19: COBRA Subsidy Under the American Rescue Plan Act of 2021–Important Deadlines Approaching

COVID-19: COBRA Subsidy Under the American Rescue Plan Act of 2021–Important Deadlines Approaching

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On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARPA), which subsidizes fully paid post-employment healthcare coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) for any “assistance eligible individual” for a six-month period from April 1, 2021, to September 30, 2021, using a 100 percent federal government subsidy for premiums paid. In addition to COBRA continuation coverage, the COBRA subsidy under ARPA applies to coverage under certain state law programs that provide comparable coverage to participants and beneficiaries, often referred to as “mini-COBRA.” The employer or plan to which COBRA premiums are payable is entitled to a tax credit for the amount of the premium assistance. As discussed in further detail below, this COBRA subsidy does not apply to any otherwise eligible employees (or other qualified beneficiaries) if the employee voluntarily terminates employment.

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