April 16, 2021

American Rescue Plan Act Update

On April 7, 2021, the DOL released guidance in the form of Frequently Asked Questions regarding the COBRA subsidy, as well as model notices that can be used when administering ARPA’s COBRA subsidy requirements. The DOL’s guidance includes:

  • FAQs about COBRA premium assistance under the American Rescue Plan Act: PDF

  • Model General Notice and COBRA Continuation Coverage Election Notice: PDF

  • Model Notice in Connection with Extended Election Period: PDF

  • Model Alternative Notice: PDF

  • Model Notice of Expiration of Premium Assistance: PDF

  • Summary of COBRA Premium Assistance Provisions under the American Rescue Plan Act of 2021:  PDF

View our full compliance alert here. And take time to review the resources above to stay informed about ARPA and the COBRA Subsidy.

HealthEquity will continue to stay abreast of this topic and – as additional guidance is available – we will advise accordingly.

March 12, 2021


On Thursday, March 11, 2021, the President signed the American Rescue Plan Act (the 'Act') which includes continuation coverage premium assistance for certain individuals and their families receiving COBRA due to an involuntary termination of employment or a reduction of hours. The Act also includes a temporary change to Dependent Care Flexible Spending Accounts (DCFSAs).

HealthEquity continues to review the legislation and has solicited guidance from several regulatory authorities to learn how to inform our clients about next steps. Once we receive concrete guidance, we will be sure to update all clients directly. You should expect additional communications from HealthEquity over the coming weeks.

HealthEquity/WageWorks’ comments requesting guidance from the agencies can be viewed here.

Clients, brokers and partners should watch the webinar where our compliance team shares the impacts the most recent legislative changes may have on benefits plans.

COVID Relief 2021: Understanding the Impact on Your Benefits Plans
Read our webinar FAQs