American Rescue Plan COBRA information for California

The recent American Rescue Plan Act of 2021 (ARP) includes new COBRA continuation coverage election, notice, and premium assistance requirements that may affect your COBRA administration. The premium assistance will be 100% of the total cost of federal COBRA and/or Cal-COBRA 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 company and Kaiser Permanente to take based on how federal COBRA and/or Cal-COBRA is currently billed.

Group billed federal COBRA and Kaiser Permanente billed Cal-COBRA

Your company, or third-party administrator, administers its own federal COBRA health coverage, and Kaiser Permanente bills members directly for any Cal-COBRA mandated coverage. Your Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA.

Employer responsibilities

For your federal COBRA population, your company is responsible for:

  1. Sending required ARP notices to your employees
  2. Paying COBRA premiums to Kaiser Permanente for assistance eligible individuals (AEIs) based on bills received
  3. Claiming the payroll tax credit

Updated July 26, 2021
For your Cal-COBRA population, your company is responsible for:

  1. Confirming that an individual is assistance eligible under ARP because of employment termination or a reduction of hours. Note: Kaiser Permanente will reach out for confirmation once a member has completed their AEI form.
  2. Paying Cal-COBRA premiums to Kaiser Permanente for AEIs, based on bills received
  3. Claiming the payroll tax credit
  4. Notifying Kaiser Permanente if an AEI has a change in eligibility
Kaiser Permanente responsibilities

Kaiser Permanente has no responsibilities for your company’s federal COBRA population.

Updated July 26, 2021
For your Cal-COBRA population, Kaiser Permanente will:

  1. Send the ARP notices to your company’s current Cal-COBRA population and include the model summary ARP notice and request to be treated as an AEI in the Cal-COBRA information packet for newly eligible members between April 1, 2021 and September 30, 2021
  2. Reach out to your company to confirm individuals are assistance eligible
  3. Transfer AEIs from direct billed to group billed
  4. Issue refunds directly to AEIs if they have already paid Cal-COBRA premiums for coverage between April 1, 2021 and September 30, 2021
  5. Bill your company retroactively for AEIs for coverage beginning on or after April 1, 2021

Kaiser Permanente billed federal COBRA and Cal-COBRA

Kaiser Permanente bills members directly for federal COBRA health coverage and any Cal-COBRA mandated coverage. The employer’s Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA.

Employer responsibilities

For your federal COBRA population, your company is responsible for:

  1. Sending required ARP notices to your employees
  2. Informing Kaiser Permanente of assistance eligible individuals (AEIs) by filling out the supplemental reporting template and sending it to:
  3. Paying COBRA premiums to Kaiser Permanente for AEIs based on bills received
  4. Claiming the payroll tax credit

Updated July 26, 2021
For your Cal-COBRA population, your company is responsible for:

  1. Confirming that an individual is assistance eligible under ARP because of employment termination or a reduction of hours. Note: Kaiser Permanente will reach out for confirmation once a member has completed their AEI form.
  2. Paying Cal-COBRA premiums to Kaiser Permanente for AEIs, based on bills received
  3. Claiming the payroll tax credit
  4. Notifying Kaiser Permanente if an AEI has a change in eligibility
Kaiser Permanente responsibilities

For your federal COBRA population, once the supplemental reporting template has been received, Kaiser Permanente will:

  1. Transfer AEIs from direct billed to group billed
  2. Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021
  3. Bill your company retroactively for AEIs for coverage beginning on or after April 1, 2021

Updated July 26, 2021
For your Cal-COBRA population, Kaiser Permanente will:

  1. Send the ARP notices to your company’s current Cal-COBRA population and include the model summary ARP notice and request to be treated as an AEI in the Cal-COBRA information packet for newly eligible members between April 1, 2021 and September 30, 2021
  2. Reach out to your company to confirm individuals are assistance eligible
  3. Transfer AEIs from direct billed to group billed
  4. Issue refunds directly to AEIs if they have already paid Cal-COBRA premiums for coverage between April 1, 2021 and September 30, 2021
  5. Bill your company retroactively for AEIs for coverage beginning on or after April 1, 2021

Kaiser Permanente billed mini-COBRA

Your company has less than 20 employees and is subject to Cal-COBRA health coverage that Kaiser Permanente directly bills members.

Employer responsibilities

Your company is responsible for:

  1. Confirming that an individual is assistance eligible under ARP because of employment termination or a reduction of hours
  2. Notifying Kaiser Permanente if an assistance eligible individual (AEI) has a change in eligibility

Kaiser Permanente responsibilities

Kaiser Permanente will:

  1. Send the ARP notices to your company’s current Cal-COBRA population and include the model summary ARP notice and request to be treated as an AEI in the Cal-COBRA information packet for newly eligible members between April 1, 2021 and September 30, 2021
  2. Reach out to your company to confirm individuals are assistance eligible
  3. Issue refunds directly to AEIs if they have already paid COBRA premiums for coverage between April 1, 2021 and September 30, 2021
  4. Claim the payroll tax credit for Cal-COBRA AEIs

Helpful resources

Guidance and notices from the Department of Labor and Internal Revenue Service:

Please contact your tax accountant or attorney for more information about ARPA requirements. If you have questions about Kaiser Permanente’s approach, please contact your account manager. Small businesses, please contact the small business account management support team at 1 800 790 4661 (option 3).