Based on additional guidance provided by the Department of Labor since our last communication, below you will find some general guidelines and resources as well as Health New England’s Administration Policy for ARPA Cobra Premium Subsidy.

The American Rescue Plan Act of 2021 (ARPA) creates a COBRA (Consolidated Omnibus Budget Reconciliation Act of 1985) premium subsidy. This subsidy is available to “assistance eligible individuals” (AEIs) and their covered dependents during the period of April 1, 2021, through September 30, 2021.

For an employee to qualify as an AEI, they generally need to meet the following criteria:

• MUST have a COBRA qualifying event that is a reduction in hours or an involuntary termination of a covered employee’s employment;
• MUST elect COBRA continuation coverage;
• MUST NOT be eligible for Medicare;
• MUST NOT be eligible for coverage under any other group health plan; and
• MUST make an election within a new 60-day period

An employee can elect to change their existing COBRA medical plan, during this period, to a lesser expensive option currently offered by the group.

Under ARPA, Employer Groups should modify their election notice to ensure individuals are informed about the new subsidies. Model Notices can be found at: https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra/premium-subsidy.

 Health New England’s Administration Policy for ARPA Cobra Premium Subsidy

 For groups with 20 or more employees:

Employees enrolled with Health New England in a Bill to Group method should receive notice about the ARPA premium assistance and premium credit from the Employer Group

Employees currently grandfathered in with Health New England under a Bill to Individual method as outlined in our Cobra Change in Billing Administration would be converted to a Bill to Group method in order for Employer Group to administer the subsidy and file for the tax credit. Employee would then remain in the Bill to Group billing method after the subsidy expiration of September 30, 2021.

 For groups with 2-19 employees:

Employees enrolled with Health New England in a Bill to Group method can receive the ARPA premium assistance credit from the Employer Group or Health New England if requested by the Employer Group. Employees should receive notice about the ARPA premium assistance from the Employer Group.

Employees currently grandfathered in with Health New England under a Bill to Individual method as outlined in our Cobra Change in Billing Administration will receive notice about the ARPA premium assistance and premium credit from Health New England. Employees may also receive notice from the Employer Group. Employer Groups can elect to change the billing method to a Bill to Group to administer the subsidy and file for the tax credit. If electing Bill to Group method, the employee would then remain in the Bill to Group billing method after the subsidy expiration of September 30, 2021.

Where Health New England is deemed the subsidy payer, the Employer Groups should remit the Request for Treatment as an Assistance Eligible Individual to billingreconciliation@hne.com.

Employer Group must be current on premiums to Health New England or have entered into a payment arrangement. If you have questions or concerns related to premium payment or need a Health New England COVID-19 Hardship Request Form, please contact Accounting or our Member Services team at the following:

• Accounting Department: accountingoperations@hne.com
• Member Services: (413) 787-4004 or toll-free (800) 310-2835 (Monday – Friday, 8 a.m. – 6 p.m.)