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Solutions / For Employees / COVID-Relief FAQs

COVID-Relief FAQs

EBSA Disaster Relief Notice 2021-01
American Rescue Plan Act of 2021

This material is for informational purposes only. It does not contain legal or tax advice. Clients should contact their legal counsel or tax advisor if they have any questions or need additional information. Information is believed to be accurate as of this production date; however, it is subject to change.
Last Updated: 3/29/2021

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COVID-19 Frequently Asked Questions

 

Outbreak Period, Generally:


QUESTION: What does “Outbreak Period” mean?


QUESTION: What deadlines are suspended during the Outbreak Period?


QUESTION: How long do the deadline suspensions last?


QUESTION: A member had a baby during the Outbreak Period. Can the member still add the baby to her coverage? 


QUESTION: A member got married during the Outbreak Period. Can the member still add their spouse to the coverage? 

 

Claims, Appeals, External Review:


QUESTION: A member went to the doctor and the member’s claim was due to be filed during the Outbreak Period. Does the deadline suspension impact how long the member has to submit their claim? 


QUESTION: A member’s health benefit plan denied a benefit claim, and the member’s appeal is due during the Outbreak Period. Does the deadline suspension impact how long the member has to file an appeal? 

 

COBRA:


QUESTION: A member’s COBRA election was due during the Outbreak Period. Does the deadline suspension impact how long the member has to elect COBRA? 


Question: A member’s COBRA premium was due during the Outbreak Period. Does the deadline suspension provide them with additional time to pay? 


QUESTION: A member elected COBRA during the Outbreak Period but has NEVER paid their COBRA premium. How long does that member have to pay? 


QUESTION: A member is enrolled in COBRA and becomes disabled during the Outbreak Period. The member has not yet notified the Plan Administrator of the disability. Does the deadline suspension provide members with additional time to submit notice? 

 

American Rescue Plan Act of 2021 (ARPA): COBRA Premium Subsidy and New COBRA Election Period:


QUESTION: What is ARPA? 


QUESTION: What COBRA relief does ARPA provide to eligible members? 


QUESTION: If COBRA members are eligible for a COBRA premium subsidy, is the insurer or employer eligible to claim a tax credit to offset the premium subsidized? 

 

General Overview with Examples

 

RELIEF: Special Enrollment Events


RELIEF: Claims, Appeals, External Review


RELIEF: COBRA Election Period


RELIEF: COBRA Premium


RELIEF: COBRA Disability

 

ARPA Frequently Asked Questions

 

QUESTION: What is the American Rescue Plan Act (ARP), and how does it impact COBRA?


 

Subsidy Questions:

QUESTION: Who is eligible for the subsidy?


QUESTION: When is the subsidy available?


QUESTION: How much premium will a qualified beneficiary owe during the subsidy period (April 1, 2021 through to September 30, 2021)?


QUESTION: How does a qualified beneficiary claim the subsidy? 


QUESTION: Can a qualified beneficiary’s subsidy end before the subsidy period end date of September 30, 2021? 


QUESTION: Should a qualified beneficiary notify their Plan Administrator when they are no longer subsidy eligible? 


QUESTION: What COBRA premium is due after the subsidy period ends on September 30, 2021?


QUESTION: Will a qualified beneficiary receive any Notice prior to their subsidy period end date? 


 

Election Period Questions:

QUESTION: Who is eligible for ARP’s new COBRA election period?


QUESTION: If a qualified beneficiary elects COBRA during the new COBRA election period, when does their COBRA coverage begin?


QUESTION: How does a qualified beneficiary elect COBRA during the new COBRA election period?


 

COBRA Plan Option Question:

QUESTION: During the subsidy period, can a qualified beneficiary elect a Federal COBRA or State COBRA plan that differs from the plan they had when they lost group health coverage?