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American Rescue Plan Act (ARPA) Action Required by May 31, 2021

By May 12, 2021February 2nd, 2023No Comments

The new American Rescue Plan Act (ARPA) provisions can be overwhelming and not the most exciting thing to read about. But they’re crucial for your company’s future, so you should know what actions your organization needs to take before the May 31st deadline.

High-level overview of ARPA:

  • ARPA subsidies cover the full cost of COBRA or mini-COBRA premiums from April 1, 2021, through Sept. 30, 2021, for employees (and their qualifying family members), if the employee lost or loses group health insurance due to an involuntary job loss or reduction in work hours. The ARPA COBRA subsidy is funded through a tax credit to employers whose plans are subject to federal COBRA or are self-insured, to the plan for multiemployer plans, and to the insurer for other plans. The credit is taken against payroll taxes.

Downloadable documents:

  1. Challenges In Offering COBRA in 2021
  2. COBRA Subsidy Provision of the ARPA

What do employers need to do?

  1. COBRA eligible groups:
    • WITH a COBRA administrator: Make sure you have read the email from your administrator and have taken action. Please reach out to us with questions.
    • WITHOUT a COBRA administrator: Determine who your Assistance Eligible Individuals are, and review the attachments for info and sample notices that you may use.
  2. Employers that are not eligible for COBRA, but are eligible Texas State Continuation aka mini-COBRA:
      • If you have a fully-insured plan with Humana, United Healthcare, BCBSTX or S&W: Watkins Insurance Group is still waiting for details.
      • If you have a level-funded plan with Aetna AFA: Your plan is eligible for Texas State Continuation. Watkins Insurance Group is still waiting for additional details.
      • If you have a level-funded plan with All Savers or Humana: Your plan is not eligible for Texas State Continuation, so no action is needed.

What is the deadline to provide notices?

  • May 31, 2021