News & Updates
The recent American Rescue Plan Act of 2021 (ARP) includes new COBRA continuation coverage election, notice, and premium assistance requirements that may affect your clients’ COBRA administration. The premium assistance will be 100% of the total cost of federal COBRA and/or Cal-COBRA health coverage and will be available for eligible individuals starting April 1, 2021 through September 30, 2021. To facilitate the new ARP requirements, there are certain actions for your clients and Kaiser Permanente to take based on how federal COBRA and/or Cal-COBRA is currently billed.
Group billed federal COBRA and Kaiser Permanente billed Cal-COBRA
The employer, or third-party administrator, administers its own federal COBRA health coverage, and Kaiser Permanente bills members directly for any Cal-COBRA mandated coverage. The employer’s Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA.
Employer responsibilities
For an employer’s federal COBRA population, they are responsible for:
For an employer’s Cal-COBRA population, they are responsible for:
Kaiser Permanente responsibilities
Kaiser Permanente has no responsibilities for the employer’s federal COBRA population. The employer sends the ARP notice to AEIs and claims the payroll tax credit.
For an employer’s Cal-COBRA population, Kaiser Permanente will:
Kaiser Permanente billed federal COBRA and Cal-COBRA
Kaiser Permanente bills members directly for federal COBRA health coverage and any Cal-COBRA mandated coverage. The employer’s Cal-COBRA population is individuals who have exhausted all 18 months of federal COBRA and qualify for Cal-COBRA.
Employer responsibilities
For an employer’s federal COBRA population, they are responsible for:
For an employer’s Cal-COBRA population, they are responsible for:
Kaiser Permanente responsibilities
For an employer’s federal COBRA population, once Kaiser Permanente receives the supplemental reporting template from the employer, Kaiser Permanente will:
For an employer’s Cal-COBRA population, Kaiser Permanente will:
Kaiser Permanente billed mini-COBRA
The employer has less than 20 employees and is subject to Cal-COBRA health coverage that Kaiser Permanente directly bills members.
Employer responsibilities
The employer is responsible for:
Kaiser Permanente responsibilities
Kaiser Permanente will:
Helpful resources
Guidance and notices from the Department of Labor and Internal Revenue Service:
Please have your clients contact their tax accountant or attorney for more information about ARP requirements. If you have questions about Kaiser Permanente’s approach, please contact your Kaiser Permanente account manager or visit account.kp.org.
For questions, please contact your B&P Sales Rep – 888.722.3373.