Update – 4/23/2021
ARPA and What To Expect Next
We anticipate having the report listing possible AEI eligible individuals emailed to our clients by Tuesday, April 27th. That communication will include detailed, specific instructions on how to move forward with notifying AEI’s of their eligibility for the subsidy if the client wishes to engage Streamline HR to do so on their behalf.
We appreciate your patience while we work through the complicated nature of this new legislation. We are committed to offering a complete solution which has taken time to incorporate as further clarification of requirements has been ongoing.
Please continue to reference our website for ongoing updates.
Update – 4/09/2021
Important dates regarding COBRA and ARPA
The DOL released Model Notices on 4/7/21 that our software partner is diligently working on to update the platform to accommodate the new regulations.
We anticipate having a report to send to clients regarding possible AEI eligible individuals the week of 4/19. Clients will need to review and advise who would be AEI eligible. Notices will then be generated around the week of 5/10.
Due to the additional work that will be required to help you be compliant with the new requirements under ARPA, there will be additional fees for our service. We hope to have those details available the week of 4/19.
At this time, we recommend reviewing your records to determine those who have been involuntarily terminated or experienced a reduction of hours that would have resulted in a loss of coverage from 11/1/19 or later. You will need that information available when we provide you with the AEI eligible report.
It has been confirmed that ARPA applies to groups that are subject to state continuation laws (under 20 employees) as well as Federal laws.
Please click on the below link that will take you to a FAQ sheet released by the DOL which helps clarify common questions surrounding the COBRA requirements according to ARPA.
Update – 3/31/2021
Assistance Eligible Individual (AEI) Notification
As we await the release of the AEI subsidy Model Notice to be released by the DOL (deadline is April 10, 2021), we encourage our clients to review their records to identify any employee who was involuntarily terminated or lost coverage due to a reduction in hours between 11/1/19 to present.
Within the next couple of weeks, Streamline HR will be emailing current Clients a list of the employees in our portal that fall into this timeframe along with instructions on how to identify who is eligible or ineligible for the subsidy. Once this is returned to us and our software platform is updated with the required notification, the eligible AEI’s will be notified of their right to continue COBRA coverage along with instructions on how to apply for the subsidized coverage.
If our COBRA administration started for your group after 11/1/19, Streamline HR will need to be notified of any potential AEI’s whose records are not in our portal. After collecting all relevant information on these individuals, we will then be able to notify them of their rights.
Streamline HR is continuing to monitor the guidance and working with our partners to meet the notification requirements. We will share additional information regarding notification and administration specifics as it becomes available.
Update – 3/16/2021
American Rescue Plan Act – COBRA Information
On March 11, 2021, the American Rescue Plan Act of 2021 (ARPA) was signed by President Biden.
ARPA includes a provision for a COBRA continuation coverage premium subsidy of 100 percent for individuals and families who experienced an involuntary termination of employment or reduction in hours.
This subsidy will be available for Assistance Eligible Individuals (AEIs), as determined by the Act, from April 1, 2021 through September 30, 2021. COBRA participants must meet the below criteria in order to be an AEI:
- Coverage was lost due to involuntary termination of employment or reduction in hours.
- The COBRA participant is still within the COBRA eligibility period as of April 1, 2021.
- Eligible COBRA participants who do not have an election in place will have the opportunity to make an election during an Extended Election Period and will be able to take advantage of the subsidy effective April 1, 2021. This will be referred to as the “lookback period” in determining member eligibility.
- Eligible COBRA participants who have an election in place as of April 1, 2021 will be able to take advantage of the subsidy effective April 1, 2021.
- Eligible COBRA participants who become eligible for COBRA continuation coverage on or after April 1, 2021 will be eligible for the subsidy while it is in effect.
ARPA requires the Department of Labor (DOL) to provide model notices within 30 days from the date of enactment — on or before April 10. The DOL model notes will be reviewed and incorporated into subsidy notices, referred to as AEI Notices. The Act requires that individuals in the lookback period, as well as those currently enrolled, receive a notification regarding the subsidy within 60 days of April 1, 2021.
Streamline HR is closely monitoring the guidance and will be working diligently with our partners to meet the administration requirements of the ARPA.