No Foolin’ – 8 Things to Know About the New COBRA Subsidy
April 1, 2021, 3:35 pm
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Curious about how the ARPA COBRA Subsidies work? Check out this article from Benefit Resource!

The American Rescue Plan Act of 2021 (ARPA) was passed through the House and Senate this week. The bill was signed into law on March 11, 2021. While the specifics are still developing, here are 8 things to know about the COBRA subsidy that is included in the bill.

1. It’s a 100% subsidy.

While there were several iterations of the bill and subsidies, the final version includes a 100% subsidy. This will allow eligible individuals to obtain COBRA continuation coverage for their health plan without paying COBRA premiums.

2. It’s specific.

The COBRA subsidy is only available for premiums due from April 1, 2021 through September 30, 2021, referred to as the subsidy period. In order to be eligible, individuals must be in their 18-month Federal COBRA Coverage period.

3. Coverage is not automatic.

While newly eligible individuals will not need to pay premiums, they will still need to elect COBRA coverage in order to take advantage of the subsidy.

4. Employers are responsible for paying premiums, but receive a tax credit.

Employers sponsoring a group health plan will be responsible for paying health insurance carriers for the premiums. They will be reimbursed for 100% of the COBRA premiums through tax credits against certain payroll taxes.

5. New and previous qualified beneficiaries may be eligible.

The COBRA subsidy is available for individuals who are or become qualified beneficiaries as a result of involuntary termination of employment or a reduction in hours. This may include individuals who:

  • become eligible for COBRA during the subsidy period
  • previously elected COBRA coverage and have paid premiums for prior months
  • have not elected COBRA coverage but are still eligible to elect COBRA

6. Eligible individuals will need to be notified.

Eligible individuals will need to receive an updated notification regarding their rights to COBRA and the COBRA subsidy. The Department of Labor and Department of Health and Human Services is expected to provide new model notices within 30-days of enactment of the law.

7. Subsidies apply to Group Health Plans, except FSAs.

The 100% COBRA subsidy applies to the underlying medical coverage, dental and vision plans. Participants may still be responsible for premiums if they elect coverage for an FSA (or other benefits being offered post-employment).

8. Individuals could elect to change coverage.

If an employer permits individuals to change coverage, the premium subsidy cannot exceed the cost of the coverage option the individual was in at the time of the qualifying event.

For example: Assume at the time of termination an employee was enrolled in Plan A and the premium was $500 per month. They have an opportunity to enroll in Plan B, but it costs $700 per month. The employee’s subsidy cannot exceed the original premium of $500 per month. 

Cyber Insurance 101


By:  Mitchell R Ledven, Insurance Advisor, Combs & Company, LLC

The current landscape of the U.S. workforce is quite different than it was six months ago. In a world once consumed by daily human interaction, we now find ourselves spending most of our days sitting in front of a screen and talking behind a keyboard. Some may say that this is just a short-term solution to the problem at hand, while others say it will be the way of life moving forward. While we don’t know for certain which answer is correct, we can agree that one thing is for sure and that is every day you log into a computer, there is a risk that someone is out there trying to take advantage of you. That person could be your next door neighbor or a 12-year-old hacker sitting in their parent’s basement on the other side of the globe.  The point of this blog isn’t to shake you out of your boots, but it is to inform you about a way to protect your business and its assets. Enter Cyber Liability Insurance, a coverage that helps protect data and operations of your business if you find yourself the victim of a cyber related attack. Here’s how it works:

Cyber Liability Insurance helps protect your business from losses resulting from online threats. These breaches can be suffered on a 1st and/or 3rd party basis. This is a responsive coverage to help soften the blow due to a cyber-attack.

What it Protects Against:

  • Username and password theft
  • Phishing emails
  • Ransomware/cyber extorsion
  • Defense costs, fines, and penalties
  • Business interruption after a cyber related incident
  • Breach response
  • Funds transfer fraud
  • Crisis management/PR
  • Website is hacked

In a Nutshell: If you store data or have systems connected to the internet, you are exposed to cyber threats.

Is it required?: No. However, all states have laws regarding breach notification. Some states have laws dictating cyber protocols. For example, NY has DFS rule 500 and the SHIELD Act, while California has the California Consumer Protection Act (CCPA).


Section 125 Considerations for Mid-Year Enrollments

Looking for an easy digestible explanation what considerations to make for Mid-Year Enrollments under a Section 125 plan? Check out this great video from colleague, Chelsea Whalley of J Donovan Financial.


Special Mid-Year Enrollment Window

1. Get Approval from Health Insurer in writing. If Self-funded, approval comes from stop-loss carrier.
2. Decide if these special deductions will be pre-tax or post-tax. As of right now, the IRS has issued no guidance for pre-tax elections due to COVID-19.

Section 125 Mid Year Election Change Events:
1. Change in employment status if the change impacts eligibility for health plan
2. A significant change in health plan coverage
3. HIPAA Special Enrollment (marriage, birth, etc)

To avoid any unintended liability, employers should check with your CPA and/or attorney to decide what is best for your business.

4 Ways to Keep Health Coverage

Here are 4 quick ways to keep your health insurance coverage by our Combs & Company friend, Chelsea Whalley of J Donovan Financial.

This is for employees who have lost coverage through an Employer Sponsored Plan.

1) COBRA- Contact your Benefits Administrator. Remember, there is no employer contribution so this is an expensive option.

2) Spouse Plan- This Qualifying Life Event (loss of coverage) creates a window of opportunity to join your spouse’s health plan. Contact your spouse’s Benefits Administrator for pricing.

3) Medicaid- A severe loss of income may qualify you for Medicaid at

4) – The QLE allows you 60 days to enroll in an individual plan on the marketplace.

Insurance 101: What is a Formulary Drug

pexels-photo-259027.jpegCheck our our quick video to understand what you need to know about Formulary Drugs!

For more Insurance 101, check our our Combs & Co YouTube Channel!

Insurance 101: What is a Flexible Spending Account

Check our our quick video about Flexible Spending Accounts (FSA)!

For more Insurance 101, check our our Combs & Co YouTube Channel!

What are Exclusive Provider Organizations (EPOs)?

Check our our quick video about Exclusive Provider Organizations (EPOs)!

For more Insurance 101, check our our Combs & Co YouTube Channel!

What are Exclusions?

Check our our quick video about what Exclusions are in an insurance policy!

For more Insurance 101, check our our Combs & Co YouTube Channel!


What are Essential Health Benefits?

When the ACA (Affordable Care Act) became law, we were introduced to many new terms.  Check our our quick video about Essential Health Benefits!

For more Insurance 101, check our our Combs & Co YouTube Channel!

What is an Evidence of Insurability?

Check our our quick video about Evidence of Insurability!

For more Insurance 101, check our our Combs & Co YouTube Channel!