ARPA COBRA Subsidy FAQs
With so much influx, one could say that right now is the most crucial time for employers, brokers, and OCA to work in tandem to ensure COBRA compliance.
American Rescue Plan Act of 2021
On March 11, 2021, the American Rescue Plan Act of 2021 (ARPA) was signed into law. On March 11, 2021, the American Rescue Plan Act of 2021 (ARPA) was signed into law. ARPA establishes a 100% COBRA premium subsidy for eligible individuals during the period beginning on April 1, 2021 and ending on September 30, 2021. Here you will find the latest ARPA regulatory updates, OCA’s COBRA process changes, and more, so that our clients are up to date will all the changes taking place.
OCA’s May 27th ARPA/COBRA Subsidy Webinar
Click the below to access OCA’s webinar focusing on the ARPA notice requirements and OCA timelines. OCA has set clear expectations to when these notices will be sent as well as the necessary action items and/or responsibilities for all the parties involved.
Subsidy Approval/Denial Confirmation Form
Employers should use this form to confirm or deny the subsidy for any potential AEIs.
OCA’s ARPA Email History
Since ARPA was signed into law on March 11, 2021, OCA has been committed to being transparent and keeping our clients informed on all of the ARPA COBRA subsidy news. Below you will find all of our client communication emails.
IRS Issues ARPA Guidance
On May 18, 2021, the Internal Revenue Service (IRS) released Notice 2021-31. The notice provides much needed information regarding the calculation of the ARPA subsidy, the eligibility of individuals, the premium assistance period, and other information vital to employers, plan administrators, and insurers to understand the credit.View Notice 2021-31
OCA’s ARPA Operational Update (Week of June 1st)
Step 1 – Identifying Assistance Eligible Individuals (AEI)
OCA has completed its list of all potentially eligible individuals for the subsidy. Remember, this was the first challenge we faced. Historically, the industry did not track voluntary vs. involuntary terminations, so it’s critical we work together to confirm the AEI list.
Step 2 – Finalize Client Communication Strategy of AEI List
This has been completed. OCA will be finalizing its AEI communication strategy with employers and brokers. OCA’s goal is to be proactive by taking a two prong approach. First, by confirming with employers/brokers the AEI list and then reaffirming eligibility when we issue the special election notice to the AEI.
Step 3 – Communicating AEI List to Clients
OCA’s dedicated COBRA team worked over the holiday weekend to ensure our clients began receiving their potential AEI list ahead of schedule. Only employers subject to Federal COBRA and who had a termination or reduction of hours in the last 17 months would have received this email. This was completed on April 5th.
Step 4 – Updating COBRA Election Notice
This has been completed as of May 11. OCA has updated our COBRA Election Notice to include the required ARPA language as well as the necessary attestation forms potential AEIs to request the subsidy.
Step 5- Issuing Extended Election Notice
OCA has issued the Extended Election notice to all potential AEIs. AEIs will then be required to remit the form back to OCA within 60 days of the notice being mailed.
Step 6- Confirm and Activate Subsidy
Once OCA receives the AEI Attestation form, OCA will reaffirm the subsidy with the employer. Once approved, the subsidy will be applied to the AEI during their subsidy eligible months. This is an ongoing effort.
This is not intended to be legal advice. Please contact your benefits counsel if you need additional guidance.
IRS Releases Notice 2021-31
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OCA ARPA Notices Timelines/Schedule
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OCA’s ARPA Communications
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