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Benefits Buzz: Department of Labor Issues COBRA Subsidy Model Notices, FAQs

Benefits Buzz: Department of Labor Issues COBRA Subsidy Model Notices, FAQs

The Department of Labor (DOL) issued FAQs and model notices for the COBRA premium assistance provisions of the American Rescue Plan Act (ARPA).

In the FAQs and notices, the DOL provides guidance on:
• Eligibility
• Elections
• Notice requirements and duration of the subsidy 

The goal of the FAQs is to provide further insight into why the federal COVID-19 related relief for plan deadlines does not apply to notice or election periods. These provisions were set forth in the ARPA about the COBRA subsidy.

Although, an individual may elect COBRA from an earlier qualifying event if the individual is eligible to make that election. This includes the extended time frames provided that relief.

In addition, the DOL provided mental health FAQs covering the Consolidated Appropriations Act, 2021 (CAA). The CAA amended the Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) to provide more protections.

These FAQs cover:
• When plans and issuers must make their NQTL comparative analyses available
• What information plans and issuers must make available
• Reasons why documentation of comparative analyses of NQTLs might be insufficient
• What types of documentation should be made available
• What actions the Departments might take for noncompliance

For more information, view the infographic provided by Integrity HRM. 

If you have any questions, please read over the notices and FAQs provided by the DOL or contact Integrity HRM at 


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