Eligibility

ARP COBRA Subsidy

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Involuntary Termination of Employment

Reduction
in Hours

Employers should interpret an involuntary termination broadly, including when an employee is terminated for cause, unless there was gross misconduct

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COBRA or state continuation triggered:

Between
April – September 2021

Prior to April 2021,
but still in maximum coverage period

Subsidy will be available to employees (former employees) and their spouses and dependents

Already Enrolled

Coverage continues
No premium is due (premium is paid by the employer for up to 6 months
COBRA subsidy must be elected within 60 days of being notified
Must still be within their maximum coverage period from the original qualifying event date

Not Enrolled

Must be given a second chance to enroll and take advantage of the subsidy
Must still be within their maximum coverage period from the original qualifying event date
Coverage must be elected within 60 days of being notified of the COBRA subsidy
Coverage is prospective (i.e., Apr. 1), not retroactive to the original qualifying event date

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Example 1

Employee experiences a reduction in hours May 12, 2021

Employee (and any family members enrolled) must be offered the COBRA subsidy for Jun. 1 – Sept. 30, 2021

Example 2

Employee’s position was eliminated Jul. 23, 2020. Employee and family elected COBRA and have paid monthly COBRA premiums since Aug. 2020

Family may continue coverage and not pay the COBRA premiums for Apr. 1 – Sept. 30, 2021

Example 3

Employee was involuntarily terminated Nov. 3, 2019. Employee did not elect COBRA when first offered

Employee must be offered the COBRA subsidy for Apr. 1 – May 31, 2021