American Rescue Plan COBRA information for Mid-Atlantic States

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 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 company and Kaiser Permanente to take based on how federal COBRA or state continuation health coverage is currently billed.

Group billed federal COBRA

Your company, or a third-party administrator, administers its own federal COBRA health coverage.

Employer responsibilities

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

Kaiser Permanente billed federal COBRA

Kaiser Permanente bills members directly for federal COBRA health coverage.

Employer responsibilities

Your company is responsible for:

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

Kaiser Permanente responsibilities

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

Group billed mini-COBRA

Your company has less than 20 employees and is subject to state continuation coverage that you administer.

Employer responsibilities

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 send it to membership-analytical-team@kp.org 
  3. Notifying Kaiser Permanente if an AEI has a change in eligibility

Kaiser Permanente responsibilities

Once the supplemental reporting template has been received, Kaiser Permanente will:

  1. Issue a reference only invoice for AEIs under the group bill name “ARP Members Do Not Pay”
  2. Issue refunds to your company for AEIs if COBRA premiums were paid for coverage beginning April 1, 2021
  3. Claim the payroll tax credit for state continuation 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.