What Constitutes an Involuntary Termination of Employment for Purposes of the ARPA COBRA Premium Subsidy?
ThomsonReuters
JULY 8, 2021
QUESTION: I understand that to be eligible for the ARPA COBRA premium subsidy, an employee must have lost group health plan coverage due to an involuntary termination of employment or a reduction of hours. For this purpose, when is a termination of employment considered involuntary? ANSWER: The 100% COBRA premium subsidy created by the American Rescue Plan Act of 2021 (ARPA) (see our Checkpoint article ) is available when certain employees (and their families) lose health coverage due to the
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