OCA remains committed to being transparent and keeping our clients informed on all of the ARPA COBRA subsidy news. 
We have provided our latest ARPA operational update below as well as launching our COBRA subsidy FAQ page. We will continue adding helpful Q&As as our open questions become clearer and additional guidance is issued. 
  
OCA's ARPA Operational Update:
 
Step 1 - Identifying Assistance Eligible Individuals (AEI)
 
Expected Completion Date: 3/24/21
 
As of Monday, March 21st, OCA is finalizing its list of all potentially eligible individuals for the subsidy. Remember, the first challenge we face is identifying who is an AEI. Historically, the industry did not track voluntary vs. involuntary terminations, so it's critical we work together to confirm the AEI list. We expect the list to be completed by 3/24/21. Click here to see the definition of an AEI. 
 
Step 2 - Finalize Client Communication Strategy of AEI List
 
Expected Completion Date: 3/26/21
 
By Friday, March 26th, 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 List to Employers/Brokers
 
Expected Start Date: 4/1/21

It's critical we work together to confirm the AEI list. If OCA does not hear from employers/brokers, we will assume the termed employee was involuntary terminated, resulting in the AEI receiving the special election notice.

When Will Notices Be Sent to AEI?
 
OCA will be mailing out a special election notice to eligible individuals with the understanding that:
    • ARPA calls for the Department of Labor to issue model notices within 30 days of April 1st  and it is very likely OCA will wait for the DOL to issue the model notice before mailing out the special election notice to eligible individuals.
    • ARPA states that the special election notice must go out within 60 days of April 1st.
    • Eligible individuals will then have 60 days after the date on which the special notice is provided, with the subsidy going back to April 1st.
    • Please note that a special per notice fee will apply.
 
What's Next?

We want you and your team to know we're on top of this and set expectations for what the next couple of months could look like. We will be back to you again with additional information and resources. To submit any questions, please click here and an OCA representative will get back to you promptly.