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What Providers Need to Know Now About ARPA COBRA Subsidies

On March 11, 2021, President Biden signed The American Rescue Plan Act of 2021 (ARPA). Included in the many pages of relief for individuals who have been adversely affected by COVID 19, is an expansion and assistance of COBRA benefits not seen since the American Recovery and Reinvestment Act of 2009 (ARRA).

Under ARPA, an employee who has had their employment involuntarily terminated, or had their hours reduced, is eligible for 6 months of free COBRA coverage. This subsidy ends on September 30, 2021. It appears the time frame was designed to catch anyone who has involuntarily lost work, since the pandemic began in April 2020, as the eligibility window for COBRA is 18 months.

Importantly, the subsidy is now available to employees who never elected COBRA coverage, or elected coverage and let it lapse. These individuals must be allowed an additional 60-day window to re-enroll. Additionally, this special election period allows those employees to make prospective elections beginning April 1, 2021, meaning they can elect to begin the 6 months of coverage without requiring payment of back dated premiums.

What does this mean for providers? According to the Congressional Budget Office, this means at least 3 million more insured patients. The CBO estimated that 2.2 million people would enroll in subsidized COBRA, joining 800,000 who would remain enrolled. This estimate was done on the House version of the bill, which only included an 85% subsidy. The 100% subsidy is expected to drastically increase, perhaps double, those numbers. In 2009, when ARRA provided only a 65% subsidy, an evaluation for the US Department of Labor showed that the COBRA enrollment rate went from 8% to 34%.

As is frequently the case, providers may be left with explaining and assisting their patients in receiving access to this subsidy, and in doing so converting self-pay balances to insured accounts. Employers are awaiting final instruction and sample notices from the Government, which is due within 45 days of signing. Once received, all eligible individuals should receive notice from their employers. However, they will not be automatically enrolled.

Providers should focus on three main areas of screening patients for this eligibility 1) high balance self-pay accounts with dates of service from April 1, 2021- September 30, 2021 2) self-pay patients scheduled for services April 1, 2021- September 30, 2021 3) patients currently being seen in any reoccurring visit environment- physical therapy, infusion, etc. It is also recommended, that providers work with any large employers in their community to assist patients, and potential patients, with enrollment.

Altum Healthcare Solutions is working with many providers to develop and execute a plan around this subsidy roll out. For more information, please contact us at

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