IRS updates COBRA subsidy guidance

The IRS has updated its guidance regarding the temporary COBRA continuation premium subsidy under the American Recue Plan Act. Please see notice N-2021-46 for full details.

Key points:

The Notice provides 11 additional questions and answers covering topics such as:

  • Extended coverage periods for Assistance Eligible Individuals (AEIs) whose original 18-month COBRA continuation coverage period has expired
  • End of the COBRA premium assistance period for AEIs who selected dental or vision coverage only
  • Who is entitled to claim the COBRA premium assistance credit when state-mandated continuation coverage (Mini-COBRA) is comparable to Federal COBRA, and is a group health plan subject to both Federal COBRA and Mini-COBRA

Employers who are premium payees should review this additional guidance carefully to ensure compliance and their ability to claim the relevant premium assistance tax credit.

Disclaimer: The information contained herein is not intended to be construed as legal advice, nor should it be relied on as such. Employers should closely monitor the rules and regulations specific to their jurisdiction(s) and should seek advice from counsel relative to their rights and responsibilities.

By Amy Leiti
Benefits and ACA Specialist, Checkwriters
Amy joined Checkwriters in 2016 as part of the benefits department, and now specializes in several areas including Affordable Care Act (ACA) compliance, reporting, and special projects. Her particular area of expertise is to advise on and implement technology solutions that assist Checkwriters' clients in efficiently delivering and managing their benefits packages. Prior to joining Checkwriters, she spent 25 years as a Licensed Insurance Broker in New England at a number of premier agencies.

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