The American Rescue Plan Act of 2021 (ARPA) became law in March. The $1.9 trillion stimulus package contains a mix of benefits, tax credits, programs, and subsidies in response to the continuing COVID-19 pandemic. Among the ARPA’s provisions are several related to COBRA. Let’s take a closer look.
How COBRA Premium Subsidy Works
The ARPA’s rules for a 100% COBRA premium subsidy apply to all group health plans subject to the Employee Retirement Income Security Act (ERISA), the Internal Revenue Code, or the Public Health Service Act, whether fully or self-insured. Church plans, although not subject to those laws, may nevertheless have to comply with some of the rules detailed below to the extent they’re subject to state continuation coverage (or “mini-COBRA”) laws.
