COBRA Subsidy FAQs

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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.

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.