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[UPDATE: On April 7, 2021, the Department of Labor issued the model notices required by ARPA, as well as an FAQ to provide additional guidance on the changes to the COBRA subsidies.]

On March 12, 2021, President Biden signed the American Rescue Plan Act (ARPA) into law, aiming to provide relief to individuals and businesses suffering from the COVID-19 pandemic. ARPA impacts employer-sponsored health plans in several ways, including the implementation of a COBRA premium subsidy. Employers should be aware of the actions they must take in response to this change.

COBRA requires an employer-sponsored group health plan to give employees who otherwise would lose coverage due to termination (or another qualifying event) a chance to continue to buy coverage for themselves and any family members on the plan for a limited period after that event. The maximum coverage period generally is 18 months. The plan typically may charge up to 102 percent of the cost of coverage for similarly situated active participants (the COBRA premium).

Continue Reading American Rescue Plan Act’s COBRA health care premium subsidy

On April 1, 2020, the Department of Labor (DOL) issued regulations implementing the Families First Coronavirus Response Act (FFCRA). In addition, DOL continues to update its FFCRA Q&As with further clarifications.
Continue Reading DOL’s new FFCRA regulations and Q&As on COVID-19 paid leave clarify documentation and other requirements

As discussed in prior blog posts, the Families First Coronavirus Response Act (FFCRA) will require covered employers to provide certain levels of paid emergency sick leave and paid Family and Medical Leave Act (FMLA) leave to employees for specified coronavirus-related reasons. In general, as explained in those posts, the minimum number of hours of the paid sick leave that employers must provide is 80 hours for full time employees, with pro-rated amounts for part time employees based on the average number of hours they work over a two week period.
Continue Reading Payroll tax credits under the Families First Coronavirus Response Act