By Matthew P. Chiarello and Nancy K. Campbell
In an effort to combat the effects of the COVID-19 pandemic, Congress passed and President Biden signed into law the American Rescue Plan Act of 2021 (“ARPA”). Among many other provisions, ARPA contains changes that significantly and immediately impact group health plans.
In particular, ARPA provides (i) a subsidy for certain insurance premiums under the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”), (ii) an opportunity for certain individuals to enroll or re-enroll in COBRA continuation coverage, and (iii) an option to elect less expensive health coverage. This Newsletter addresses each of these provisions.
Important Note: Some issues under ARPA are not entirely clear and additional guidance from the government is expected to help resolve these uncertainties.