Hunton Employment & Labor Perspectives

The Departments of Labor, Treasury and Health and Human Services (collectively, the Departments) recently issued new guidance in the form of FAQs to plan sponsors and administrators of group health plans to assist with them with preparations for the end of the COVID-19 National Emergency and the Public Health Emergency.[1] [2]

The American Rescue Plan Act (“the Act”) signed in March 2021 provides for a 100% COBRA premium subsidy for certain individuals who are eligible for and enroll in COBRA coverage between April 1, 2021 and September 30, 2021. Employers sponsoring health plans should take action quickly to ensure that the subsidy is properly administered and consider its effects on any planned layoffs or other severance events.