NADP has received several questions about the implementation of the American Rescue Plan’s 100% subsidy of COBRA premiums including:

  • Eligibility determinations
  • Impact on fully insured plans
  • Avenues of tax credit reimbursement for carriers

NADP is working to develop resources for members on the COBRA subsidies and will be providing updates as they develop. In the meantime, NADP is encouraging members to post any questions, issues, or comments on COBRA subsidy issues in the “American Rescue Plan COBRA Premium Subsidy Implementation” discussion in the Advocacy Open Forum in Dental Interact. The COBRA subsidy language from the 2021 relief bill is nearly identical to the language in the 2009 American Recovery and Reinvestment Act.  See links below to resources from 2009 that may be useful in refreshing your teams on the details of COBRA premium subsidies. While the implementation in 2021 may look somewhat different, these resources are good background information.

IRS Q&A (2009)
IRS Whitepaper and Guidance (2009)
IRS COBRA Subsidy Landing Page (Updated 2015)
SHRM Press Release on ARPA (2021)

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