All individuals eligible will receive a new COBRA election notice in the mail. The notice will describe and detail who is eligible and how to enroll.
To be eligible for a subsidy, ALL of the following must apply:
- Individual is a qualified beneficiary with a qualifying event under COBRA;
- The qualifying event occurs on or after November 1, 2019;
- The individual elects coverage (again, the new notice will detail how to elect);
- The individual does not have any other offer of employer-sponsored coverage or access to Medicare coverage.
Individuals who previously declined or discontinued COBRA coverage are still eligible to receive the subsidy as long as they are still within their coverage period. The individual must enroll within 60 days of the notice they receive.
Individuals who experience a 2nd qualifying event will be eligible for the subsidy.
Individuals who elect COBRA under the subsidy do not have to pay retroactively to the date of coverage but can choose to have coverage begin on April 1, 2021.
Currently, the ARPA guidance does not address whether the subsidy applies if an individual has a 2nd qualifying event but further guidance is anticipated.