The American Rescue Plan Act of 2021 (ARPA), signed into law March 11, 2021, provides relief for individuals eligible for continuation coverage under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) as a result of involuntary termination from employment or reduction in hours. The relief comes in the form of a 100% COBRA premium subsidy for the six-month period beginning April 1, 2021, and ending September 30, 2021. Below is a summary of key highlights and issues to consider as employers and plan administrators scramble to comply with these new requirements.

What plans are subject to the ARPA requirements? These new requirements apply to group health plans subject to COBRA (both fully and self-insured) as well as health plans subject to similar continuation coverage requirements under applicable state laws (commonly known as “mini-COBRA” laws). Although not entirely clear, these requirements also appear to apply to dental and vision plans as well as health reimbursement arrangements (HRAs). However, they do not apply to health flexible spending arrangements (FSAs). Continue reading >