On April 7th, the United States Department of Labor issued detailed guidance and model notices to assist employers in implementing the COBRA premium assistance requirement under Section 9501 of the American Rescue Plan Act of 2021 (the ARP).

The ARP requires employers to provide a 100 percent COBRA premium subsidy – between April 1, 2021 and Sept. 30, 2021 – for employees whose reduction in hours or involuntary termination of employment makes them eligible for COBRA continuation coverage during this period. An employer or plan to whom COBRA premiums are payable, advances the COBRA premium and is then entitled to a tax credit for the amount of the premium assistance provided.Continue Reading American Rescue Plan Act of 2021 Requires Employers to Pay Employee COBRA Premiums Until September 30, 2021