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COBRA

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 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

Document Description
General Notice and COBRA Election Notice To be given 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.
Extended Election Periods Notice To be given to all qualified beneficiaries who had a qualifying event that is a reduction in hours or an involuntary termination of employment before April 1, 2021.
Premium Assistance Application Employers and individuals who qualify for the subsidy should complete this form.
Expiration of Premium Assistance To be given to all Assistance Eligible Individuals 15-45 days before their premium assistance expires.

 

Mini-COBRA for Employers with 2-19 Employees

Carrier Instructions Document
All Carriers Employers and individuals who qualify for the subsidy should complete this form. 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. 

Carrier Instructions Document
Harvard Pilgrim Health Care HPHC Instructions HPHC Attestation
THP Direct THP Direct Instructions THP Direct Attestation
Tufts Health Plan Tufts Health Plan Instructions Tufts Health Plan Attestation

For more information



MINI-COBRA CONTINUATION OF COVERAGE BENEFITS

The Massachusetts small group continuation of coverage law (Mini-COBRA) requires small group carriers to provide for the continuation of health benefits to employees of small businesses with 2-19 employees. Mini-COBRA allows employees and their family members to continue coverage on their small group health benefit plan and pay group rates for certain time periods under circumstances where they previously would have lost coverage.

While COBRA and Mini-COBRA are similar, they are not identical and do contain differences. Some differences include:

1.  COBRA is a federal law and is not enforced by the Division of Insurance.  Mini-COBRA is a state law                       and is enforced by the Division of Insurance.

2.  COBRA generally applies to group health plans offered by employers with 20 or more employees.
      Mini-COBRA applies to small group health benefit plans issued to employers with 2-19 employees.

3.  COBRA applies to self-funded plans and group health plans offered by employers with 20 or more
      employees. Mini-COBRA does not apply to self-funded plans.

   Qualified Beneficiaries and Qualifying Events under Mini-COBRA

Mini-COBRA benefits must be provided to Qualified Beneficiaries upon the occurrence of a Qualifying Event. Qualified Beneficiaries are generally individuals who are covered under a small group health benefit plan on the day before the Qualifying Event. Qualified Beneficiaries can be:

1.  An employee.

2.  The spouse of an employee.

3.  The dependent child of an employee.

Qualifying Events are events which would cause a Qualified Beneficiary to lose health coverage if Mini-COBRA benefits were not available. The type of Qualifying Event will determine: (1) who is eligible for MINI-COBRA and (2) the length of time that the benefits must be offered.

Massachusetts law requires employees of small groups (2-19 employees) be offered Massachusetts Continuation of Coverage (COC), the health insurance carriers delegates this obligation to small employers.  Group acknowledges that it is responsible for administering COBRA/COC, including without limitation, providing all required notices.

For more information, please review the MiniCobra Continuation of Coverage Benefits Guide


Forms and Documents for Employers


 Document              Description
Continuation of Coverage Election Form   To be given to employee                             
Employer Group Overview   Overview explains the process                    
COC Rights Notice   Explains employee's rights
Unavailability of Continuing Coverage   To be used when employee is ineligible  
Early Termination Notice   Sent by employer if coverage is terminating