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Health Plan Options

Premium Assistance for COBRA Benefits Under the American Rescue Plan Act

 

As a follow up to our communication sent on July 8th, 2021, below are revised instructions for producers to access, complete and submit Assistance Eligible Individual Verification and Enrollment Contact Forms on behalf of clients to UPMC Health Plan:

1. Log into Producer OnLine and click on Resource Center.
2. Click on Forms + Applications on either 2-50 Small Group or 51+ Group, and scroll down to and select “ARPA Assistance Eligible Individual Verification Form."
3. Download the form first, then complete and save it. (Please note that to complete the form electronically, the form must be downloaded first.)
4. The saved ARPA Assistance Eligible Individual Verification Form now needs to be attached to the Enrollment Contact Form.  In Producer OnLine, click on Resource Center.
5. Click on Forms + Applications on either 2-50 Small Group or 51+ Group, and scroll down to Enrollment Contact Form.
6. On the form, select “Producer,” next select “ARPA” from the dropdown.
7. Complete form, attach the ARPA Assistance Eligible Individual Verification Form, and submit.

As a reminder, here is the original message that was shared:


The American Rescue Plan Act (ARP), enacted in March 2021, provides for a temporary 100 percent federal subsidization of premium otherwise payable by certain individuals and their families who elect COBRA continuation coverage due to a loss of coverage as the result of a reduction in hours or an involuntary termination of employment. COBRA premium assistance is available for “Assistance Eligible Individuals” (AEI) as of the first period of coverage beginning on or after April 1, 2021, and ending September 30, 2021. An Assistance Eligible Individual is a COBRA-qualified beneficiary who meets the following requirements during the period from April 1, 2021, through September 30, 2021:

  • Is eligible for COBRA continuation coverage by reason of a qualifying event that is a reduction in hours (such as reduced hours due to change in a business’s hours of operations, a change from full-time to part-time status, taking of a temporary leave of absence, or an individual’s participation in a lawful labor strike, as long as the individual remains an employee at the time that hours are reduced) or an involuntary termination of employment (not including a voluntary termination); and
  • Elects COBRA continuation coverage.

 
Premium assistance is not available if an individual is eligible for coverage under any other group health plan or for Medicare. If an individual receiving premium assistance becomes eligible for coverage under any other group health plan or for Medicare, the premium assistance period ends. Eligibility for coverage under any other group health plan does not terminate eligibility for COBRA premium assistance if the other group health plan provides only excepted benefits, is a health flexible spending arrangement (FSA), or is a qualified small employer health reimbursement arrangement (QSEHRA).

The ARP requires that health insurance issuers and group health plans treat Assistance Eligible Individuals as having paid the full amount of their COBRA premium for the specified coverage and plans and issuers should not collect premium payments from Assistance Eligible Individuals during the applicable time period. The person to whom premiums for COBRA continuation coverage are payable (the employer, insurer, or multiemployer plan, as applicable) is entitled to a refundable tax credit for the amount of the premium assistance. 
 
An employer may allow an Assistance Eligible Individual to elect coverage different from the coverage under the plan in which the individual was enrolled before the reduction in hours or involuntary termination of employment, and COBRA premium assistance will apply with respect to that newly elected coverage. 
 
The premium for the different coverage option that is offered may not exceed the premium for the coverage the individual had before the reduction in hours or involuntary termination of employment. The temporary premium assistance is also available to individuals enrolled in continuation health coverage under State programs that provide for coverage comparable to COBRA continuation coverage, often referred to as “Mini-COBRA.”
 
ARP Extended Election Period
 
The ARP provides an extended election period for certain individuals who did not have an election of COBRA continuation coverage in effect on April 1, 2021. The ARP extended election period is available for an individual who would be an Assistance Eligible Individual if the individual had a COBRA continuation coverage election in effect on April 1, 2021, or an individual who previously elected COBRA continuation coverage and discontinued that coverage before April 1, 2021 (assuming they have outstanding months of COBRA coverage eligibility).  
 
The ARP extended election period continues for 60 days after these individuals are provided notice of the extended election period. This additional election period does not extend the period of COBRA continuation coverage beyond the original maximum period.
 
Unlike the ARP Premium Assistance, the ARP extended election period applies only to a group health plan that is subject to Federal COBRA. It does not apply to plans subject to continuation coverage requirements under a State program that provides comparable continuation coverage. However, if a State law or program provides for a similar extended election right and an individual otherwise satisfies the requirements to be an Assistance Eligible Individual, COBRA premium assistance is available for any resulting period of COBRA continuation coverage for periods of coverage from April 1, 2021, through September 30, 2021. 
 
Notice Requirements
 
Under the ARP, plans and issuers are required to notify qualified beneficiaries regarding the premium assistance and other information about their rights, including:

  • A general notice to all qualified beneficiaries who have a qualifying event that is a reduction in hours or an involuntary termination of employment from April 1, 2021, through September 30, 2021. This notice may be provided separately or with the COBRA election notice following a COBRA qualifying event.
  • A notice of the extended COBRA election period to any Assistance Eligible Individual (or any individual who would be an Assistance Eligible Individual if a COBRA continuation coverage election were in effect) who had a qualifying event before April 1, 2021. This requirement does not include those individuals whose maximum COBRA continuation coverage period, if COBRA had been elected or not discontinued, would have ended before April 1, 2021. This notice must be provided within 60 days following April 1, 2021 (that is, by May 31, 2021).  Potential Assistance Eligible Individuals must elect COBRA continuation coverage within 60 days of receipt of the relevant notice or forfeit their right to elect COBRA continuation coverage with premium assistance.

 
UPMC Health Plan* has already distributed these notices to AEIs for groups where UPMC Health Plan acts as the COBRA administrator.

The ARP also requires that plans and issuers provide individuals with a notice of expiration of periods of premium assistance explaining that the premium assistance for the individual will expire soon, the date of the expiration, and that the individual may be eligible for coverage without any premium assistance through COBRA continuation coverage or coverage under a group health plan. This notice must be provided 15-45 days before the individual’s premium assistance expires. UPMC Health Plan will send these applicable notices for groups where UPMC Health Plan is the COBRA administrator.

Instructions for submitting Assistance Eligible Individual Verification Forms to UPMC Health Plan:

1. Log into Producer OnLine and click on Employee Coverage.
2. Click on the Enrollment Contact Form.
3. Select Producer, next select "A.R.P.A." from the dropdown.
4. Complete form, attach document, and submit.
 
For Frequently Asked Questions regarding premium assistance for COBRA Benefits under the American Rescue Act Plan, click here.

* UPMC Health Plan is the marketing name used to refer to the following companies, which are licensed to issue individual and group health insurance products, or which provide third party administration services for group health plans: UPMC Health Network, Inc., UPMC Health Options, Inc., UPMC Health Coverage, Inc., UPMC Health Plan, Inc., UPMC Health Benefits, Inc., UPMC for You, Inc, Community Care Behavioral Health Organization, and/or UPMC Benefit Management Services, Inc.