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All Things ARPA

August 18, 2021

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Subsidy End Period Notices. Part of the American Rescue Plan Act requires that AEIs be notified of their subsidy end period. Flores will be sending notices to all enrolled AEIs via regular mail, notifying them of the subsidy coming to an end. The target date will be to send these the week of August 23rd.
  • Flores will be creating a memo to be sent to brokers first, then clients that the subsidy end notices are in circulation. We are targeting this memo to go out via Kim’s Constant Contact eBlast next week, but could be the following week.
  • The DOL language that will be included in the notice is attached. This is saved to the DMS.
  • The notice will go to anyone who has “ARPA enrolled” selected as “YES” in the PV through 9/30/21. It will also be sent to anyone who has ‘Manual’ selected.
  • There will be a copy of the notice scanned into/saved in the participant’s account.
  • There is no fee for this service.
  • Even if Flores did not handle the lookback, we will still send the subsidy expiration notices.
ARPA Reporting: As a reminder, a report detailing individuals who are currently having their COBRA premium subsidized is generated and posted monthly to the employer portal. This report is titled ‘ARPA 2%’ and is posted to the “File History” page of Flores DASH. This is the report that your clients should use when requesting their tax credit.
  • October invoices will be held by one week. They are scheduled to be sent on 9/7/2021. This will help ensure participants who are actively receiving the ARPA subsidy will receive the required subsidy expiration notice before they are billed for October premiums.
  • We anticipate roughly 2000 notices notifying of the AEI Subsidy coming to an end. THANK YOU in advance to our fabulous Shared Service team for helping to get these out.
Best Practice – The ARPA team thought it would be helpful to share some phrasing for questions we anticipate receiving in the coming weeks.
    • Q: Why did I receive a notice that my subsidy is ending?
    • A: The COBRA premium assistance subsidy provided under the American Rescue Plan Act is only for periods of coverage between 4/1/2021 – 9/30/2021. This notice is to inform you that as of 10/1/21 you will be responsible for your COBRA premiums in full, as they are no longer eligible to be subsidized.
    • Q: Will Flores be making updates if the subsidy period is extended, or there are changes to deadlines?
    • A: Yes, Flores is monitoring all updates from the DOL and should any changes be made to the ARPA subsidy timeline we will promptly update all impacted individuals.
    • Q: What if a participant elects COBRA and is an AEI receiving the subsidy after the subsidy expiration notices are sent? Does the participant still need to receive a notice of expiration? Do I need to send it manually?  
    • A: The American Rescue Plan Act requires that notice of the COBRA premium subsidy expiration date of 9/30/2021 be sent within 15 to 45 days before the expiration date. We are consulting with IT to see if it will be possible to run the subsidy routine again on 9/15/2021 after the bulk mailing is done next week. Ideally, this will capture any participants who elect after the routine is run but are still required to receive the expiration notice. There has not been guidance stating AEIs who elect COBRA and to receive the subsidies after 9/15/2021 (15 days prior to 9/30/2021) must receive notice of the subsidy expiration.