Ameriflex is unable to determine if a previously-terminated employee was terminated voluntarily or involuntarily without the employer providing and confirming such information. As the custodian of employment records, the employer is responsible for reporting this information accurately; therefore, it is crucial employers review their COBRA records to ensure those employees who were terminated beginning November 1, 2019 to present were marked correctly as involuntary or voluntary.
Action Items for Ameriflex Clients
March 29, 2021 – May 7, 2021: Review COBRA Records – Employer Responsibility
- Review Information and Submit Updates. Instructions on how to do this can be found here.
- Deadline: To ensure all individuals who are eligible for the subsidy receive their notices in the required timeframe, please notify your Client Relationship Team of any changes by May 7th.
Action Items for Ameriflex and Department of Labor
April 10, 2021 – Department of Labor Responsibility
- Election model notice will be issued (within 30 days of ARPA enactment date)
May 14, 2021* – May 31, 2021 – Ameriflex Responsibility
- Ameriflex will mail the special COBRA election notice to individuals who have been involuntarily terminated or had a reduction in hours and who are still in their 18-month COBRA coverage period at no additional cost. Qualified Beneficiaries must elect within 60 days of being provided the new election notice. *Date subject to change pending DOL-provided notice.
April, 25, 2021 – Department of Labor Responsibility
- Subsidy Expiration model notice will be issued (within 45 days of ARPA enactment date)
May 31, 2021* – September 15, 2021 – Ameriflex Responsibility
- Ameriflex will mail the Subsidy Expiration Notice to enrolled Qualified Beneficiaries no more than 45 days, and no less than 15 days, prior to the premium subsidy expiration date at no additional cost. *Date subject to change pending DOL-provided notice.
Employers will be able to offset the cost of the COBRA subsidy through a payroll tax credit against the Section 3111(b) Medicare tax. The credit will include the entire COBRA premium, including the 2% administrative fee. More information and guidance on the tax credit procedures will be forthcoming as the IRS and DOL work to determine the exact procedure.