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Important ARPA Subsidy Update for Employer-Sponsored Health Plans Subject to New Jersey State Continuation

On Wednesday, July 21, the New Jersey Department of Banking and Insurance (DOBI) issued Bulletin No. 21-08 establishing an additional notice requirement for small employers sponsoring fully-insured group health plans subject to NJ State Continuation (i.e. NJ “mini-COBRA”) pertaining to the American Rescue Plan Act’s (ARPA) COBRA subsidies.

 
Prior to DOBI issuing No. 21-08, small employers sponsoring fully-insured group health plans subject to NJ State Continuation were only required to provide notice of the availability of subsidies for NJ State Continuation to the following Assistance Eligible Individuals:

  1. Qualified beneficiaries who were either terminated involuntarily, or experienced a reduction in hours and were still within their election period on April 1, 2021;
  2. Qualified beneficiaries already enrolled in NJ State Continuation as of April 1, 2021; or
  3. Qualified beneficiaries who were/are involuntarily terminated or had/have a reduction in hours between after April 1, 2021 but before September 30, 2021.

Now, Bulletin No. 21-08 requires small employers sponsoring fully-insured group health plans subject to NJ State Continuation whose employees had the opportunity to elect continuation due to reduced hours, furloughs or layoffs, but who did not elect continuation or who elected continuation but later terminated it, must be given the opportunity for an extended election period. These employers subject to State Continuation must provide notice of the extended election period no later than five (5) business days following July 21, 2021.

Bulletin No. 21-08 directs employers use the Alternative Notice of ARP Continuation Coverage Election Notice that has been modified for use with New Jersey Continuation.

As with any legislative change, we’ll continue to monitor any updates or changes made.

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