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American Rescue Plan Act of 2021 (ARPA)
The American Rescue Plan Act of 2021 (“ARPA” or “the Act”) was signed by President Biden on March 11, 2021. The Act includes a wide variety of provisions designed to provide various areas of relief for individuals and businesses struggling due to COVID-19.
100% COBRA Continuation Coverage Premium Subsidy for Individuals and their Families
The Act provides COBRA premiums for “assistance eligible individuals” to be subsidized by the federal government, through payroll tax credits, for a period of six months, beginning on April 1, 2021 and ending on September 30, 2021.
• What is the subsidy amount? 100% of the cost of premiums during the “Period of Coverage” timeframe of April 1, 2021 and when the subsidy is set to expire on September 30, 2021, subject to otherwise applicable maximum periods of coverage (typically 18 months) under COBRA.
• Who is eligible for the COBRA premium subsidy? Any “assistance eligible individual” is who loses coverage due to an involuntary termination of employment or because of an involuntary reduction of hours, and who would otherwise be eligible during timeframe between April 1, 2021 and September 30, 2021 (“Period of Coverage”), including:
- Individuals who lose coverage during Period of Coverage due to an involuntary termination of employment or because of a reduction of hours
- Individuals who lost coverage and did not elect COBRA but would otherwise have been eligible for the premium subsidy during Period of Coverage.
- Individuals who elected and terminated coverage prior to 4/1 and who would otherwise be eligible for the premium subsidy.
• What does it mean to be an assistance eligible individual? Defined generally as including any employee or dependent who loses group health plan coverage due to an involuntary termination of employment or because of a reduction of hours.
• What is the maximum coverage period of COBRA premium assistance? For any assistance eligible individuals who are enrolled or enroll in COBRA due to this subsidy, the subsidy that will be in effect from April 1-Sept 30th “Period of Coverage” will end earlier if the individual’s maximum period of COBRA coverage ends prior to September 30th, or if they become eligible for coverage under another group health plan or Medicare. It is important to note that individuals who fail to notify their group health plan if they become eligible for other coverage or Medicare will be subject to the greater of a $250 penalty or 110% of the premium subsidy provided after loss of eligibility.
• How does the special election period work? The Act also creates a special election period for any individual who did not elect federal COBRA continuation coverage but who otherwise would have been eligible for the COBRA subsidy and for any individual who elected federal COBRA continuation coverage and discontinued such coverage before April 1, 2021. These individuals will be able to elect COBRA coverage within 60 days of receiving the required employer notice. The resulting COBRA continuation coverage begins with the first period of COBRA continuation coverage beginning on or after April 1, 2021 – making the special election prospective instead of retroactive to what their original effective date for COBRA coverage or when their coverage originally lapsed.
• How do employers claim a credit for the subsidy amounts? Employers will obtain the subsidy that they must provide to assistance eligible individuals, through a payroll tax credit against employers’ quarterly taxes. If the credit exceeds the amount of payroll taxes due, the credit would be refundable when employers submit Form 941, their quarterly tax return. The credit could also be advanced under rules that will be set by the Treasury Department.
• How and when will assistance eligible individuals receive notice? The Act tasks the Department of Labor (DOL) and Internal Revenue Service (IRS) with issuing regulations and guidance on the COBRA subsidy provisions of the Act. In addition, the Act requires the DOL to produce model COBRA election notices within 30 days of enactment and a model COBRA premium subsidy expiration notice within 45 days of enactment.
Coordination of COBRA Premium Subsidy and Extension of COBRA Deadlines
To complicate matters further, the individuals who are eligible for the extended COBRA deadlines, clarified in guidance issued on February 26, 2021, will also be eligible for subsidy provisions if they meet the eligibility requirements as assistance eligible individuals. As a reminder, the COBRA extension deadline relief we refer to here provides that COBRA deadlines that otherwise would occur during the “outbreak period” (the period beginning March 1, 2020 and ending 60 days after the announced end of the presidentially declared national emergency) must be tolled until the earlier of one year from the date the deadline otherwise would have applied or the end of the outbreak period.
Temporary Increase to Dependent Care Flexible Spending Account Maximum Limit for 2021
Another of the several provisions included in the Act is the option for employers to increase the maximum amount that may be contributed to an employee’s Dependent Care FSA from $5,000 ($2,500 married filing separately) to $10,500 ($5,250 married filing separately). Retroactive amendments will be permitted if an amendment is adopted by the last day of the 2021 plan year and the plan is administered consistently with the terms of the amendment beginning on its effective date. This relief will be in addition to the optional unlimited carryover and/or extended grace period from the relief enacted on December 27, 2020 under the Consolidated Appropriations Act, 2021.
Temporary (Optional) Extension of FFCRA Tax Credits for Paid Sick and Family Leave
The provisions of Families First Coronavirus Response Act (FFCRA) that required employers with fewer than 500 employees to provide federal paid sick leave and family leave expired on December 31, 2020. The Act does not reinstate the requirement to provide paid FFCRA sick leave. However, it does temporarily extend a tax credit to employers who voluntarily choose to provide eligible employees with Emergency Paid Sick Leave or Emergency Family Medical Leave from the previous optional extension date of March 31, 2021 to the new extension date of September 30, 2021.
New Web Portal - VBA Gateway
Register for our new Web Portal VBA Gateway.
You should receive a letter with your Registration Code in the mail. If you do not receive this or need any assistance getting registered, please contact SAS Customer Service.
Please navigate to https://sas.vbagateway.com/. Choose Click here to register and/or enroll. Choose Provider Portal to register.
Please contact SAS Customer Service for assistance at 228.865.0514.
Important information regarding COVID-19
Coronavirus Testing Coverage Mandate
On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act. While the Act addresses a whole host of matters, including extended emergency FMLA expansion and paid sick time, the Act also provides coverage mandates for all group health plans, irrespective of whether the plans 1) are grandfathered, 2) are non-ERISA and/or 3) only provide preventive benefits. Indeed, the only apparent carve-out are plans that solely constitute excepted benefits.
As a result, Select Administrative Services will be waiving member cost share for screening and testing related to COVID-19 until further notice.
With regard to treatment beyond testing, the Participant will be responsible for applicable deductibles, coinsurance and any other cost-sharing requirements.
In an effort to assist our members in receiving the care they need while following the shelter-at-home order, Select Administrative Services will also allow telehealth screenings for non-COVID-19 related illnesses and routine examinations until further notice. Regular copay, deductible and coinsurance amounts will apply.
Place of Service 02 should be billed for any claim provided for telehealth services which include Virtual Check In (G2012) and Telephone E&M (99441 - 99443). A modifier is not required.
Select Administrative Services will reimburse providers $8 per patient visit for dates of service from 5/1/2020 - 6/30/2020 to help cover the costs associated with PPE supplies resulting from COVID-19. Providers should bill procedure code D1999 - Unlisted Preventive Procedure, by report.
Changes to COBRA due to COVID-19
The Departments of Labor (DOL) and Treasury, in consultation with the Department of Health and Human Services (DHHS) issued new rules imposing mandatory timeframe extensions for several employee benefits compliance requirements. The rules come in response to President Trump’s March 13, 2020 Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak, and the invocation of an emergency determination under Stafford Act beginning March 1, 2020.
These new rules impact: The HIPAA Special Enrollment Period, The COBRA Election Period, The COBRA Premium Payment Period, COBRA Notices from Employees, Health Plan Benefit Claim filing Deadline, The ERISA Adverse Benefit Determination Appeal Deadline, Rules around deadlines for and external review of an adverse claim decision and the deadline to Submit Additional Information related to External Review requests.
The extensions of employee and dependent timeframes run from March 1, 2020 until 60 days after the announced end of the National Emergency period.
The COBRA Election Period
Under COBRA, employees and dependents who lose active coverage as a result of a qualifying event have 60 days to elect continuation coverage from receiving the COBRA election notice.
The new rule extends the 60-day COBRA election period to 60 days after the end of the Outbreak Period to elect COBRA.
The COBRA Premium Payment Period
Under COBRA, qualified beneficiaries have 45 days from the COBRA election to make the first premium payment, and subsequent monthly payments are to be made within the 30-day grace period that starts at the beginning of each coverage month.
The new rule extends the 45-day initial premium payment and 30-day grace period for subsequent premium payment timeframe until 60 days after the announced end of the National Emergency period. However, after the 30-day grace period claims will be denied until payment is receive then claims will be reprocessed.
COBRA Notices from Employees re Divorce, Child Reaching Age 26, and Disability
Under COBRA, the employee or dependent is responsible for notifying the plan within 60 days of the following qualifying events:
- A divorce or legal separation causing the spouse to lose plan eligibility;
- A child losing eligible dependent status (typically upon reaching age 26).
For a COBRA qualified beneficiary to qualify for a disability extension of the maximum coverage period from 18 to 29 months, the qualified beneficiary must (among additional requirements) notify the plan within 60 days of the SSA disability determination. Failure to timely notify the plan of these events can cause the employee or dependent to lose COBRA rights under the plan.
The rules extend the 60-day employee COBRA notification timeframe.
The National Emergency ends 60 days after the Outbreak Period ends, the employee/spouse would have until 60 days after the end of the Outbreak Period to notify the plan of the divorce qualifying event and preserve COBRA rights for the former spouse.
We’re monitoring the COVID-19 pandemic closely and will be updating this site with new information as it’s available. Be sure to check back frequently for updates.
Members, You can now View and Print your ID Card online!
Log into your Gateway Member Account today to see this new feature for SAS members.
- Click on the View/Print ID Card tab.
- You can either Print or Download a copy of the card to your computer or phone.
New Coordination of Benefits E-Form Available
You can now complete and submit your annual Coordination of Benefits form online through your member account in Gateway.
- Click on the Create a Request tab.
- Click on Upload Document.
- Click on the Fillable COB Form.
- Fill out the form and download it to your computer.
- Once you have filled out and saved your PDF form, click the NEXT button below to proceed to form submission.
- Click Upload My File and select the file you just completed.