ARPA COBRA Premium Subsidies Instructions and Forms

ARPA temporary subsidy program for federal COBRA and state mini-COBRA

The American Rescue Plan Act (ARPA) is a federal law that includes a temporary program to subsidize 100% of premium costs for individuals on COBRA between April 1 and September 30, 2021. While COBRA is overseen by the federal government, these subsidies also apply to mini-COBRA for 2-19 employees that is regulated by the Massachusetts Division of Insurance.

Who qualifies for the temporary subsidy program?

•  To qualify an individual must first be eligible for COBRA because of involuntary termination or a reduction in hours.
• He or she must not be eligible for coverage through another group health plan (for example through a spouse or new employer).
• The individual also must elect COBRA
•  An individual must not be enrolled or eligible for coverage through Medicare.

Who covers the cost of the temporary subsidy?

• Employers with 20 or more employees are required to cover the cost of the subscriber premium but may then seek reimbursement through a credit on their federal payroll tax filing.
• Employers with 2-19 employees, the health insurance carriers will pay the subscriber premium for mini-COBRA.

ARPA Forms and Documents for Employers

For more information

To review the “FAQs about COBRA Premium Assistance Under the American Rescue Plan Act of 2021, click here.

Mini-COBRA for Employers with 2-19 Employees

How the health insurance carriers will administer the Mini-COBRA subsidy

• The employer and individuals must complete the Premium Assistance Application. 

 In addition, the employer must complete the Mini-COBRA Subsidy Attestation Form if enrolled in Harvard Pilgrim Health Care, THP Direct or Tufts Health Plan. 

• Once completed, all forms should be sent to HSA Insurance at billing@hsainsurance.com. 
• It is important to note that while the health insurance carriers will administer the subsidy, the employer is responsible for all other COBRA requirements, including sending out all required notifications to COBRA-eligible individuals.

What happens once someone qualifies for the subsidy

• HSA Insurance requires that the individual be billed separately rather than be included on the employer’s monthly bill.  Once the individual qualifies, HSA Insurance will post premium assistance credits to the individual’s account. 
• Once the individual qualifies, no premium amounts should be collected from that individual while they are eligible. If the individual is not determined to be eligible until after their initial eligibility date has passed, and premiums have already been collected for the relevant time period, those premium amounts should be refunded or credited to the subscriber.
• Once an individual begins receiving the subsidy, it will continue until September 30, 2021 when the subsidy ends; or the individual becomes eligible for coverage through a group health plan or Medicare at any time; or the individual’s underlying COBRA eligibility ends at any time because they have reached the end date of their term of COBRA eligibility.