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Understanding ARPA COBRA Subsidies
IMPORTANT: Clients will have ongoing responsibilities and will benefit from some of our resources. Please make sure to visit the TAKE ACTION and RESOURCES support pages.
This section of our COBRA subsidy support site is geared toward education about both the subsidy and Igoe’s processes around the subsidy. Some of these processes require employer action. Please take some time to watch the tutorials and visit the additional TAKE ACTION and RESOURCES support pages. Don’t forget to look out for our Friday newsletters. For copies, scroll down to the Newsletter Library at the bottom of this page.
Listen to this 11-minute tutorial to understand how to manage AEI eligibility throughout the ARPA subsidy period. This tutorial also provides an overview of the ongoing notification and AEI attestation process.

Listen to this 3-minute tutorial to learn about the new AEI status field and how you can keep that field updated by using a new report and import utility designed for this purpose, The AEI Maintenance Utility. This tutorial includes a step by step walk through of the utility so that your user experience is seamless.

Listen to this 9 minute tutorial to understand how to access and read the Remittance Report. This will be the primary tool you will use to communicate ARPA subsidized premium to your payroll vendor or tax preparer when claiming your tax credit or requesting a refund from the government. Use this step by step guide if you need help retrieving your on demand COBRA activity reports.

IRS Guidance was released on May 18th, 2021. Igoe is in the process of reviewing that guidance so that we can update information in this tutorial and provide a new “What the Notice Changed/Clarified” tutorial for individuals that listened to our original recording.

COBRA Subsidy
IMPORTANT: Notice 2021-31 was published on May 18th. Igoe is in the process of reviewing this Notice with appropriate compliance counsel and will update materials and resources, if content is impacted, as soon as possible.

The American Rescue Plan Act (ARPA) was recently signed into law and includes the ability for certain individuals (Assistance Eligible Individuals or AEIs) to have their COBRA coverage fully subsidized between the months of April 1, 2021 and September 30, 2021.

This subsidy applies to group health plans that provide continuation coverage under the Internal Revenue Code, ERISA, and PHSA and to state continuation coverage that is comparable to COBRA (aka “mini-COBRA”). Group health plans includes medical, dental, vision, HRAs, and some EAPs. Health FSAs are not included.
The Outbreak Period is still in effect which means that COBRA enrollment and payment deadlines cannot be enforced. Download our Outbreak Flyer to learn more.

Continue to Step 2 to take action and complete a Statement of Work

For questions, contact your Client Relations Executive or our compliance team.
Compliance can be reached @ [email protected]