Additional COBRA Premium Assistance Guidance Under ARPA

In response to the requirements under the American Rescue Plan Act of 2021 (ARPA) to provide model notices and additional guidance in relation to COBRA premium assistance, the Department of Labor has issued model notices and frequently asked questions (FAQs). The FAQs confirm the following.

• Premium assistance will apply to all group health plans subject to COBRA, except health flexible spending arrangements (including major medical, dental, and vision).
• Premium assistance will also be available for group health insurance that is required by state mini-COBRA laws.
• Assistance-eligible individuals will not need to pay administrative fees that they would normally be charged.
• Assistance-eligible individuals must elect COBRA within 60 days of receiving their notice of premium assistance. This deadline is not extended by the guidance based on the Joint Notice and the EBSA Disaster Relief Notice 2021-01.
• Individuals who are eligible for COBRA but have not elected coverage can choose to start their coverage as of April 1, 2021, and do not have to elect any coverage retroactively before that date.