Earlier this month, the Department of Labor (DoL) released model notices for plans and FAQs on the implementation of  the Consolidated Omnibus Budget Reconciliation Act (COBRA) subsidies authorized in the American Rescue Plan Act of 2021 (ARP). Please see below for a summary of the guidance, and links to the model notices. NADP is also expecting the Internal Revenue Service (IRS) to release guidance on the implementation of the COBRA subsidies soon.

In short – the guidance states:

  • Dental plans are included in the premium subsidies.
  • State Mini-COBRA plans are eligible for premium subsidies.
  • Individuals who were at one point enrolled in COBRA, lost coverage, and are still within the original 18-month timeframe of coverage may re-enroll for the duration of the coverage period during the months when subsidies are available.
  • Plans must send an extended election notice to any COBRA eligible individual to inform them they are eligible for COBRA subsidies. From that point individuals will have 60 days to elect coverage if they wish to receive subsidies.

Contact Senior Government Relations Analyst Owen Urech for more information.

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