Massachusetts Advisory Session: Your American Rescue Plan Act Questions Answered

On March 11, 2021, the American Rescue Plan Act of 2021 (ARPA) was signed into law by President Biden.

In addition to providing direct assistance to many Americans, the legislation also contains numerous provisions related to direct federal subsidies for COBRA continuation coverage, changes to the Families First Coronavirus Response Act (FFCRA) and additional support to encourage vaccinations. Read more about the ARPA provisions here. 

Along with raising the 2021 contribution limits for Dependent Care Flexible Spending Accounts (FSAs), the ARPA includes a 100% COBRA subsidy for up to six months for individuals who lost health coverage because of involuntary termination or reduction of hours during the pandemic. ARPA also provides an extended election period for those who would be eligible to receive the subsidy but did not initially elect COBRA or who let their COBRA coverage lapse. Read more about employers’ top ARPA COBRA-related questions here.  

Although employers are no longer required to offer FFCRA, the ARPA extends the tax credit from prior legislation for eligible employers that voluntarily continue to offer covered leave through September 30, 2021, and, among other updates, increases the maximum per-employee tax credit that employers can receive. Regulations regarding the ARPA, COBRA subsidy and FFCRA are forthcoming and the Internal Revenue Service (IRS) and Department of Labor (DOL) are planning to issue guidance to clarify implementation procedures in the near-term future.  

View the employer advisory session, Your American Rescue Plan Act Questions Answered: COBRA Subsidies, DCFSA, FFCRA and Current Vaccine Landscape for information, guidance and resources on the ARPA and employers’ next steps. Click the button below to access the session and resources. 

LAUNCH SESSION

 To dive into the American Rescue Plan Act in further detail, visit our Stimulus Guidance Section of the COVID-19 HUB. 

Disclaimer: Please note that this information is as we know it now and these answers are subject to clarification and/or amendment based on the release of final regulations. We will update this post as more guidance is released. The information within this article and on this site is intended to provide guidance only and is not intended as legal advice. All reasonable efforts have been made to ensure the accuracy of the information contained herein. OneDigital shall not be liable for reliance by any individual or organization upon the contents of this site. This Employer Q&A is made available by OneDigital for educational purposes only. Please consult with your local advisory team member for advice specific to your situation.