There are potential penalties for employers and individuals who are not in compliance with the COBRA subsidy rules. For Employers or Plan Sponsors: Employers who
Yes. Until an individual is notified that they are eligible for a COBRA subsidy, active COBRA participants should pay premiums. Active COBRA participants who have
Plan sponsors are responsible for paying premiums to the carrier and will receive a tax credit against their quarterly payroll taxes. The specific process to
If the individual intended to have continuous coverage, they would be responsible for any premiums incurred prior to April 1, 2021. If an individual intends
AEIs will have 60 days from notification to elect coverage under the subsidy. Coverage can be reinstated retroactively to April 1, 2021. AEIs who are
All Assistance Eligible Individuals (AEIs) will have a second election period in which they can elect coverage under the subsidy even if they did not
AEIs must be notified no later than May 31, 2021 of their right to coverage and will have 60 days to elect coverage.
Model General Notice and COBRA Continuation Coverage Election Notice For use by group health plans for qualified beneficiaries who have qualifying events occurring from April
No. Anyone who meets the eligibility requirements and is within their eligible COBRA period (generally 18-months) is eligible for a second election period and may
The COBRA government subsidies are based on the amount the AEI is responsible for. If coverage is already being subsidized, it would not also receive
Current guidance indicates that if an individual has access to another group plan, they would not be eligible for a subsidy.
There has not been clear guidance on the definition of voluntary vs. involuntary termination. Plan sponsors must use their best judgment when identifying assistance eligible
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