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DOL Issues Guidance on COBRA Subsidy Under the American Rescue Plan Act of 2021

As discussed in our previous article, the American Rescue Plan Act of 2021 (ARP) has presented a number of new administrative and operational challenges to employers.  As was the case with the FFCRA, the Department of Labor (DOL) has released guidance to help answer some of the questions and provide clarification in the form of COBRA-related FAQs, providing both general information and specific issues related to premium assistance under the ARP.

The DOL also released model notices reflecting changes to COBRA election periods, responsibility for premiums under the ARP, as well as employee notification prior to the expiration of premium assistance.  Employers can review the full list of the DOL’s COBRA guidance here to familiarize themselves with the new requirements to ensure that they are in compliance.

The Labor and Employment attorneys at Berchem Moses are available to assist you in navigating the new changes brought on by the ARP and other COVID-19 related challenges and will continue to keep you up to date on any new guidance as it becomes available.