The recent American Rescue Plan Act of 2021 (ARP) includes new COBRA continuation coverage election, notice, and premium assistance requirements that may affect your clients’ COBRA administration. The premium assistance will be 100% of the total cost of federal COBRA or state continuation health coverage and will be available for eligible individuals starting April 1, 2021 through September 30, 2021. To facilitate the new ARP requirements, there are certain actions for your clients and Kaiser Permanente to take based on how federal COBRA or state continuation health coverage is currently billed.
The employer, or a third-party administrator, administers its own federal COBRA health coverage.
For an employer’s federal COBRA population, they are responsible for:
Kaiser Permanente responsibilities
Kaiser Permanente has no responsibilities for the employer’s federal COBRA population. The employer sends the ARP notice to AEIs and claims the payroll tax credit.
The employer has less than 20 employees and is subject to state continuation coverage that the employer administers.
The employer is responsible for:
Once the supplemental reporting template has been received, Kaiser Permanente will:
Guidance and notices from the Department of Labor and Internal Revenue Service:
Please have your clients contact their tax accountant or attorney for more information about ARP requirements. If you have questions about Kaiser Permanente’s approach, please contact your account manager.