The American Rescue Plan Act (ARPA), signed into law on March 11, 2021, requires employers to provide subsidized COBRA coverage to employees (and family members) who qualify for COBRA due to an involuntary termination of employment or reduction in hours. Employers are required to offer subsidized COBRA coverage between April 1 and September 30, 2021 (the “Subsidy Period”). Today, April 7, 2021, the Department of Labor's Employee Benefits Security Administration published a new webpage with resources for employers, advisers, and workers about the COBRA premium assistance under ARPA, including frequently asked questions (FAQs) and model notices. The guidance is available at: https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra/premium-subsidy.
If you have any questions regarding this Alert or other employee benefits issues, please contact Tiffany Downs, partner in our Atlanta office and head of FordHarrison’s Employee Benefits practice group at tdowns@fordharrison.com. Of course, you can also contact the FordHarrison attorney with whom you usually work.