The American Rescue Plan Act (“ARPA”) and COBRA Assistance

The American Rescue Plan Act (“ARPA”) signed into law on March 11, 2021, creates a 100 percent subsidy for COBRA coverage premiums from April 1, 2021, through September 30, 2021, and allows for COBRA enrollment even if a person declined coverage earlier or if their enrollment window closed. These provisions in ARPA are also applicable to state continuation of coverage programs, often referred to as mini-COBRA. These programs are generally available to employees of small employers (fewer than 20 employees) or other entities not subject to COBRA. Mini-COBRA programs are not uniform across states. Businesses should consult with their tax and benefits specialists for further detail and guidance.

Further details regarding the ARPA and provisions applicable to employers will be posted in the next few days.

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