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COBRA Subsidy FAQs

COBRA guidance

1 minute read

The IRS published frequently asked questions (FAQs) on the American Rescue Plan Act subsidies for continuation of health coverage under COBRA. The FAQs cover a variety of topics including how to calculate and claim the credit.

The FAQs further clarify that:

  • Health Reimbursement Arrangements, dental-only plans, and vision-only plans are covered by the subsidy
  • Involuntary termination includes constructive discharge and termination for cause. It excludes gross misconduct
  • The subsidy is available for extended periods of COBRA coverage between April 1 and September 30, 2021, due to a disability, second qualifying event, or extension under state mini-COBRA

Employers should review the FAQs and ensure that they are in compliance, especially with respect to notice and documentation obligations.

Download the bulletin for more details.

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This blog is intended to be a compilation of information and resources pulled from federal, state, and local agencies. This is not intended to be legal advice. For up to the minute information and guidance on COVID-19, please follow the guidelines of the Centers for Disease Control and Prevention (CDC) and your local health organizations.

National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Steve Smith

Steve Smith

Steve Smith is a powerhouse of energy, living by the mantra "work hard, play hard." As an expert in uniting teams for a greater purpose, Steve's innovative and creative strategies in employee health and wellness are game-changers. With over 25 years of expertise in health insurance, covering compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning, Steve is the go-to expert for driving down utilization trends and fostering a culture of well-being. His clients trust him to deliver exceptional results, making him an invaluable asset in the industry. As an Employee Benefits Consultant, Steve specializes in health care consulting for Minnesota public sector organizations including fully insured, self-insured, and stop-loss plans. Steve is a licensed insurance agent and holds the designations for Managed Healthcare Professional (The Health Insurance Association of America), Certified Patient Protection and Affordable Care Act Professional (National Association of Health Underwriters), and Group Benefits Disability Specialist (Hartford School of Insurance).