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With additional information on the ARPA COBRA subsidy, we have some additional direction to provide to you. First a quick recap:

The American Rescue Plan Act of 2021 (ARPA) provides for a 100% federal subsidy of COBRA medical premiums (excluding Health FSAs) during the period April 1, 2021 through September 30, 2021 for those who experienced an involuntary termination, or reduction in hours, causing them to lose group health coverage. Aside from the loss of coverage they:

  1. Must have been in their COBRA eligible period as of April 1, 2021, whether they enrolled or not, AND
  2. Must not be eligible for other coverage during the subsidy period. 
 
These people are referred as Assistance Eligible Individuals (AEIs).

We previously contacted you with the information we had available at that time. Now need to make sure you have identified your AEIs so we can move to the next phase:
How Do I Identify My AEIs?
We previously asked you to make sure that the COBRA event types you’ve provided to us are accurate, as we will be using these event types to determine who should be sent the Department of Labor Subsidy Notice.

If you haven’t done this already, please follow the attached to pull your AEI lookback report. (If you have already updated us, you don't need to do anything further.)

Make your updates to indicate Eligible or Ineligible on the report, and return the report to your Account Manager by May 3. Or, you can update the information directly in the “Event” tab in the Qualified Beneficiary's (QB's) record in the employer portal (refer to screenshot below).
What If I’m Not Sure Of The Exact Event Type For Someone?
Contact your Account Manager no later than May 3rd so they can assist you. It is important that you provide accurate statuses in our system. Anyone in an Unknown status will be updated to Eligible to ensure they get the Notice and compliance is maintained. Note there is a fee to you for each Notice sent.

When Is Benefit Strategies Sending Subsidy Notices?
We will be sending them as soon as possible after our system functionality is released on May 15th through the Notice mailing deadline of May 31st.

Are The Notices Required To Be Sent?
Yes, DOL regulations require all identified AEIs be sent the Notice.

What Will We Be Charged For The Notice Mailing?
Benefit Strategies understands this is an unexpected expense to employers, as it is to us. We have worked hard to keep costs down as much as possible. The fee for the Subsidy Notice will be $15 per Notice for all AEIs required to be notified. This fee will be charged regardless of your billing method.

For employees newly experiencing qualifying events during the subsidy period, we will be incorporating the subsidy language into their Qualifying Event Notices. We are doing our best to add this language while keeping the page count to an amount that will not push the QE Notice out of the standard envelope postage costs normally incurred. We will notify you as soon as possible if we need to add a surcharge. DOL requires this language be included with all Qualifying Event notices during the subsidy period, regardless of event reason.

What Should I Expect Next?
This depends on the specific population of AEIs. Those in the “look back” period identified as being AEIs have different steps than those that experience an event during the subsidy period.

Click the link below for our AEI Webpage for next steps for: 1) those in the lookback period who are currently enrolled in COBRA; 2) those in the lookback period not currently enrolled in COBRA; 3) those who are newly experiencing a Qualifying Event through September 30, 2021.

Are There Any Other Notices That Are Required To Go Out Regarding The Subsidy?
Yes, the DOL requires a Subsidy Expiration Notice be sent at the end of the AEIs subsidy window:

  • This is only for AEIs that completed the Attestation and received the subsidy
  • The DOL requires the Notice be sent 15-45 days prior to the subsidy end date
  • The Notice will be available by May 31
  • Clients will be charged $15 per Subsidy Expiration Notice sent
All of us at Benefit Strategies have worked hard to make this complex information easy for you to understand by building charts, process flows, instructional aids, and keeping you updated with emails as new information is released. We will continue to do this to keep you in full compliance. We appreciate the time and cost employers bear with ARPA. We value your partnership and will continue to support you as we navigate through the end of ARPA.

Thank you,
Benefit Strategies, LLC