American Rescue Plan Act of 2021

On today’s episode, Misty Baker and Dave Mordo are discussing ARPA, the American Rescue Plan Act of 2021.

On April 7, new guidelines and further information were released about the act. It’s important to understand that employers are responsible for this law and notifying their recipients. There are 5 new notices detailing different scenarios to aid employers in enacting the policy.

The first notice is called Model ARP General Notice and COBRA Continuation Election Notice. It’s important to remember that to understand your eligibility, you have to disclose voluntary and involuntary termination or reduction of hours. There’s still no definitive answer regarding severance packages and how they fit in - are they classed as voluntary or involuntary? We still have to wait for further clarification.

The next notice is regarding Premium Assistance. This one is a little more detailed in its questions and focuses on your eligibility for another group plan. If you are eligible for other group coverage, you don’t qualify for the COBRA subsidy. The third notice is about continuation coverage. The trouble with this one is trying to follow the money with state continuation. We don’t know how the carrier is going to provide the money. Be mindful of your own state’s regulations for election on to state continuation.

The fourth notice covers those already enrolled in COBRA. Remember, it’s up to your employer to pay the premiums and it does cover family members. The final notice is the Expiration Premium Assistance form. You have to instruct the recipient when their assistance starts and when it runs out. This means COBRA administrators have to track each individual to ensure compliance.

For best practice, ensure you can track all employees involuntarily terminated from November 1, 2019, until today. Know where the notices are and send them out to everyone.

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