COBRA Subsidy Provisions of the American Rescue Plan Act
March 24, 2021

Highlights

Eligible Individuals

The subsidy is generally available to people who elected COBRA, become eligible for COBRA, or declined or discontinued COBRA and are still within their original COBRA coverage period.

Funding

The subsidy is funded by a refundable, advanceable credit against payroll taxes taken by employers or carriers.

Option to Switch Coverage

The ARPA allows covered individuals to switch to similarly priced health coverage, if the employer allows it.


Important Dates

April 1, 2021

ARPA 100% subsidy begins to cover COBRA premiums.

Sept. 30, 2021

ARPA subsidy provision for COBRA premiums expires.


The American Rescue Plan Act (ARPA), signed into law March 11, 2021, provides a 100% subsidy of premiums for employer-sponsored group health insurance continued under the Consolidated Omnibus Budget Reconciliation Act of 1986 (COBRA) and similar state continuation of coverage (mini-COBRA) programs.


ARPA subsidies cover the full cost of COBRA or mini-COBRA premiums from April 1, 2021, through Sept. 30, 2021, for employees (and their qualifying family members), if the employee lost or loses group health insurance due to an involuntary job loss or reduction in work hours. The subsidy applies to people who are still within their original COBRA or mini-COBRA coverage period, for the length of that coverage period, even if they declined or dropped COBRA or mini-COBRA coverage earlier.

The subsidy does not apply to:


  • Individuals whose job loss was voluntary or the result of gross misconduct; or
  • Individuals who are eligible for another group health plan or Medicare.


The subsidies are funded through a payroll tax credit. Employers are required to provide new notices about the subsidy to employees. The U.S. Department of Labor (DOL) will issue model notices for this purpose.


Action Steps

Employers should familiarize themselves with the provisions of the ARPA and watch for agency guidance on its implementation.


Overview

COBRA requires group health plans to allow covered employees and their dependents to continue their group health plan coverage when it would be lost due to specific events, such as a termination of employment or reduction in working hours. Individuals are usually allowed to continue their COBRA coverage for 18 months, although some similar state mini-COBRA laws mandate a longer coverage period.


Under COBRA, group health plans may require those covered to pay 102% of the premium for their continuing health insurance, leading many eligible individuals to decline coverage. The ARPA subsidy covers the full cost of COBRA or mini-COBRA premiums from April 1 - Sept. 30, 2021, for “assistance-eligible individuals.”


Covered Plans

The COBRA subsidy in the ARPA applies to group health plans subject to federal COBRA or to a state mini-COBRA program. Plans subject to federal COBRA are plans maintained by employers with 20 or more employees on more than 50% of the business days in the previous calendar year. Small-employer plans, small governmental plans and church plans are not subject to federal COBRA, but may be subject to a state mini-COBRA law and therefore be covered by the ARPA’s COBRA subsidy provisions. 


Health flexible spending arrangements under Section 125 cafeteria plans are not covered by the ARPA COBRA subsidy.


Eligible Individuals

Individuals are eligible for the COBRA subsidy if they:


  • Are a qualified beneficiary of the group health plan; and
  • Are eligible for COBRA or mini-COBRA continuation coverage because of the covered employee’s involuntary termination (unrelated to gross misconduct) or reduction in hours of employment.


The subsidy is not available for people who voluntarily left their job. It is also unavailable for people who are eligible for Medicare or another group health plan, not including:


  • A plan covering only excepted benefits;
  • A qualified small employer health reimbursement arrangement; or
  • A flexible spending arrangement.


Furthermore, individuals receiving a COBRA subsidy who become eligible for a group health plan or Medicare must inform the health plan for which they are receiving the subsidy of that fact, or face a penalty. The premium subsidy is not counted as gross income.


Extended Election Period

The ARPA allows individuals to elect subsidized COBRA if they:


  • Become eligible for COBRA or mini-COBRA due to involuntary job termination (not caused by gross misconduct) or reduction in hours between April 1 and Sept. 30, 2021;
  • Previously declined COBRA or mini-COBRA after becoming eligible due to involuntary job termination (not caused by gross misconduct) or reduction in hours, but would still be within their COBRA or mini-COBRA coverage period had they elected the coverage at that point; or
  • Previously elected COBRA or mini-COBRA but discontinued the coverage before April 1, 2021.


The election period for subsidized COBRA under ARPA begins on April 1, 2021, and runs until 60 days after the date individuals receive notice from the health plan of the availability of the COBRA subsidy.


Duration of Coverage

COBRA and mini-COBRA coverage under the ARPA election extension starts with the first period of coverage beginning on or after April 1, 2021, and continues through the end of the individual’s COBRA or mini-COBRA coverage period. The individual’s COBRA or mini-COBRA coverage period is the period that would have applied had the individual elected the continuation coverage when first eligible following the initial qualifying event. For individuals who previously elected COBRA or mini-COBRA, discontinued it, and are now using the ARPA extended election period to obtain COBRA, the COBRA coverage period is calculated as if they had not dropped the coverage.


Switching Coverage

The ARPA contains a provision that—at the employer’s option—allows individuals eligible for the COBRA subsidy and enrolled in the employer’s group health plan to change to different health coverage also offered by the employer. The new coverage cannot have a higher premium than the individual’s previous coverage, and it must be offered to similarly situated active employees. The option does not apply to plans that provide only excepted benefits, to qualified small employer health reimbursement arrangements or to health flexible spending arrangements.

The change must be elected within 90 days of the employee receiving notice of the option.


Notice Requirements

The ARPA imposes new COBRA notice requirements on health plans.


General Notice

Plan administrators must provide notification of COBRA benefits under ARPA. The notice must be written in clear and understandable language, and it must inform recipients of the availability of ARPA premium assistance and the option under the ARPA to enroll in different coverage (if the employer permits the option).


The notice must be provided to individuals who become eligible for COBRA or mini-COBRA during the period of April 1 - Sept. 30, 2021. In addition, it must be provided by May 31, 2021, to people who have already elected COBRA coverage, and to people subject to the ARPA election extension—that is, people eligible for the subsidy who declined or discontinued COBRA or mini-COBRA before April 1, 2021.


The notification may be included in an amendment to a plan’s existing notices or be given in a separate notice, but it must contain the following information:


  1. The forms necessary for establishing eligibility for premium assistance
  2. The name, address and telephone number necessary to contact the plan administrator and any other person maintaining relevant information in connection with premium assistance
  3. A description of the extended election period under the ARPA
  4. A description of the obligation of qualified beneficiaries to notify the plan if they become eligible for another group health plan or Medicare, and the penalty for failure to do so
  5. A prominently displayed description of the right to a subsidized premium and any conditions on entitlement to the subsidized premium
  6. A description of the option of the right to enroll in different coverage (if the employer permits this option)


The DOL is charged with issuing a model general notice by April 10, 2021, for plans to use to meet the general notice requirement.


Notice of Expiration of Subsidy

Plans must also provide individuals eligible for the ARPA subsidy with notice of its expiration. The notice must be written in clear and understandable language, and inform recipients that:


  • The premium assistance will expire soon, prominently identifying the expiration date; and
  • The individual may be eligible for coverage without premium assistance through COBRA continuation or a group health plan.


Plans are not required to issue an expiration notice to individuals whose subsidy is expiring because they became eligible for other group health plan coverage or Medicare.


The notice must be provided during the 45 - 15-day period before the individual’s subsidy expires. The DOL must issue model expiration notices by April 25, 2021.


Tax Credit

The ARPA COBRA subsidy is funded through a tax credit to employers whose plans are subject to COBRA or are self-insured, to the plan for multiemployer plans, and to the insurer for other plans. The credit is taken against payroll taxes. It can be advanced (according to forms and instructions to be provided by federal agencies) and is fully refundable. The credits will be provided each quarter in an amount equal to the premiums not paid by assistance-eligible individuals.

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Your Guide to 4th of July Fun, Fireworks, and Celebrating Safely in Ontario County

June 30, 2025
The Fourth of July is almost here, and communities across Ontario County are gearing up for a weekend filled with parades, fireworks, and hometown celebrations. Whether you're heading out for live music and lawn games or simply enjoying time with friends and family, there are plenty of ways to celebrate locally. At Simco, we’re proud to support our neighbors with practical tips to enjoy the holiday safely, while making sure your insurance coverage is up to date and ready for the unexpected. Where to Watch Fireworks in Ontario County JULY 3 Farmington – Fireworks at dusk with food trucks and live music starting at 6 PM (Farmington Town Park) Honeoye Lake – The beloved “Ring of Fire” lights up the lake, with parking available at Sandy Bottom Park JULY 4 Canandaigua – Lincoln Hill Farms hosts an all-day celebration (1–10 PM) with fireworks after dark, music, games, and more. ($30 parking, cash only) JULY 5 Canandaigua North Shore – Keep the celebrations going with another round of fireworks at dark JULY 11 Geneva – Free Summerfest fireworks at 9:45 PM at the Geneva Recreation Center Parade Lineup JULY 3 Honeoye – Parade at 7 PM from United Church to Sandy Bottom Park. Stick around for the Honeoye Community Band and the Ring of Fire afterward! JULY 4 Canandaigua – The city’s annual 4th of July Parade kicks off at 10 AM from City Hall and heads south along Main Street JULY 12 Geneva – Firefighters Parade begins at 7 PM on Exchange Street, ending at the Geneva Rec Center for SummerFest festivities What Fireworks Are Legal in New York? While fireworks are a staple of July 4th, not everything that sparks and explodes is legal in New York State. Using illegal fireworks can actually void your insurance coverage if something goes wrong. What’s Allowed in NY: Ground-based or handheld sparkling devices (like cylindrical fountains or cones) Wooden sparklers/dipped sticks Party poppers Snappers (the small “pop” ones) What’s Not Allowed (and Not Covered): Aerial consumer fireworks Firecrackers Chasers Roman candles Skyrockets Bombs (even small ones!) Metal wire sparklers (they burn much hotter than they look) Quick Tip: If it launches into the sky or explodes, it’s not legal. Stick to sparklers and save yourself a potential insurance headache. Insurance Tips for a Safe Holiday A little awareness goes a long way in protecting your home, family, and peace of mind this 4th of July. Stay within NY guidelines. If an incident is caused by illegal fireworks, your insurer may deny the claim. Keep safety front and center. Supervise all activities involving sparklers or devices and keep water nearby for emergencies. Know what your policy covers. Not every homeowner’s policy includes damage from fireworks-related accidents. If you’re unsure, reach out. We’re happy to review your coverage. Report incidents quickly. Prompt reporting helps ensure claims are handled smoothly and effectively. From All of Us at Simco We’re wishing you a joyful, memorable, and safe Independence Day. Whether you’re lighting up the sky with sparklers or relaxing lakeside with family, we’re here to help you protect what matters most, before, during, and after the festivities. Have questions about your insurance coverage this summer? 📞 Call us at 585-394-5482 or visit our Contact Us page.

Understanding Accent Discrimination in the Workplace: How Employers Can Lead with Inclusion

June 25, 2025
As organizations continue to grow and diversify, the way we communicate at work is evolving, bringing new opportunities for inclusion as well as potential blind spots. One issue that often goes overlooked is accent discrimination: the tendency to judge, exclude, or undervalue individuals based on their speech patterns, dialect, or pronunciation. While accents are often rooted in geography, heritage, or culture, bias toward or against certain ways of speaking can influence decisions in hiring, promotions, evaluations, and daily interactions. For employers, particularly those in small to mid-sized organizations, understanding where this shows up and how to respond isn’t just about creating a respectful workplace. It’s also essential for risk mitigation and legal compliance. What Constitutes Accent Discrimination? Accent discrimination occurs when employees or candidates are treated unfairly due to the way they speak. This type of treatment may stem from overt, conscious bias, such as assuming someone is less capable based on how they sound, or from more subtle, unconscious preferences, like favoring those who speak in what’s perceived as a “standard” or “neutral” accent. Legally, accent-based discrimination can be considered a form of national origin discrimination, which is prohibited under Title VII of the Civil Rights Act. Many states reinforce these protections through their own civil rights laws. Employers should be aware that even unintentional practices, such as informal communication preferences or subjective feedback, can result in compliance issues or reputational damage. Clear Communication vs. Discriminatory Practice It is important to distinguish between legitimate communication needs and bias. In certain narrowly defined circumstances, an accent may be relevant to an employee’s ability to perform essential duties. For instance, in roles that require precise, real-time verbal communication, such as emergency response or high-risk operational jobs, an employer may need to assess whether a language barrier or speech pattern materially interferes with safety or accuracy. However, such evaluations must be backed by objective evidence and a clearly defined business necessity. Vague discomfort, personal preference, or client feedback based on unfamiliarity are not valid reasons to deny someone an opportunity. Any decision related to an accent must be both job-related and supported by measurable performance impacts. Standardize Hiring and Promotion Processes to Minimize Bias One of the most effective ways to reduce the risk of discrimination is by formalizing your hiring and promotion practices. Employers should examine whether their processes allow room for bias (conscious or unconscious) to influence decisions. Subjective impressions, especially in interviews or internal evaluations, can be disproportionately shaped by how a person speaks. To counteract this, companies should move toward structured, competency-based hiring frameworks. Use consistent criteria and scoring systems across all candidates, and rely on written assessments or role-specific tasks where appropriate. Similarly, promotions should be guided by documented performance metrics, not informal perceptions of professionalism or communication style. In doing so, not only do you reduce the chance for bias to affect outcomes, but you also make better staffing decisions that reflect skills, qualifications, and organizational fit: not speech patterns. Why This Matters More Now In today’s hybrid and remote work environments, the ability to navigate diverse communication styles has become even more important. With teams collaborating across geographic regions and cultural backgrounds, inclusivity in communication is essential for morale, cohesion, and productivity. Moreover, younger workers and job seekers are placing a high value on belonging and inclusion. Discriminatory or exclusionary behavior, intentional or not, can quickly erode trust and lead to disengagement or turnover, especially when tied to identity-based characteristics like accent or dialect. Employers who lead with fairness in communication are more likely to attract and retain talent, maintain strong teams, and avoid costly compliance missteps. Building a Culture Where All Voices Are Valued Ultimately, embracing different accents in the workplace is about genuine, judgment-free listening. Employers should encourage active listening practices, create space for respectful clarification when needed, and ensure employees feel safe speaking up, regardless of how they sound. Miscommunication is a solvable issue. Discrimination is not. Leaders who prioritize clarity, fairness, and consistency, rather than conformity, build workplaces that are both inclusive and high-performing. And the benefits go beyond compliance. They create environments where people thrive because they are heard and valued.

Balancing Holiday Time Off Requests Without Slowing Down Your Business

June 18, 2025
With summer travel in full swing and Labor Day just around the corner, expect a surge in time-off requests, and for good reason. Employees need time to recharge, spend time with family, and enjoy the season. For employers, especially in small to mid-sized businesses, this means finding the delicate balance between fostering a supportive work culture that respects employees’ need for time away and managing the practical realities of maintaining adequate coverage, meeting deadlines, and keeping operations running smoothly. The good news? With thoughtful planning, clear communication, and the right tools in place, you can navigate this busy season effectively, ensuring your team gets the rest they deserve without compromising business continuity. Here are a few practical strategies to help you manage PTO during the summer months while keeping your business running smoothly: 1. Plan Early and Communicate Clearly Encourage employees to submit holiday PTO requests well in advance. Set a clear internal deadline (e.g., “All holiday time-off requests must be submitted by August 15”) and explain the process upfront, including: How requests will be reviewed and approved How overlapping requests will be handled Any blackout dates or essential coverage periods A clear and consistent approach eliminates guesswork, reduces friction, and helps everyone feel they’re being treated fairly. 2. Use a PTO Policy That Balances Fairness and Flexibility Your time-off policy should include guidelines for high-demand periods like Thanksgiving, Christmas, and New Year’s. Some companies use: First-come, first-served approvals A rotation system so everyone eventually gets prime time off A seniority or department-based system with built-in equity checks Whatever method you choose, consistency is key. A well-documented policy gives managers a framework to follow, and gives employees peace of mind that decisions are made justly, not arbitrarily. 3. Leverage Your HCM or Scheduling Technology If you're using a system like isolved , you already have powerful tools to streamline the PTO process. Automate request tracking, visualize department coverage in real time, and flag conflicts early to avoid blind spots. This gives HR and team leads the visibility they need to make smart, timely decisions. Bonus tip: Use system alerts to notify managers when coverage is thin, or configure it to close PTO windows automatically after a set date. These features take manual work off your plate while protecting productivity. 4. Cross-Train and Create Holiday Coverage Plans Rather than scrambling when someone’s out, prepare your team to adapt. Cross-train employees in advance so they can cover essential tasks if a teammate is unavailable. Before the busy season kicks in, put together a simple holiday coverage plan that outlines: Who will monitor essential tasks (client inquiries, payroll processing, etc.) What needs to get done and by whom each week Who’s available for backup support if needed A little upfront planning makes a big difference in keeping service levels steady during staff absences. 5. Appreciate Those Who Step Up Don’t let holiday contributions go unnoticed. Employees who work through the holidays or shift their schedules to ensure coverage deserve meaningful recognition. Consider: Spot bonuses or incentives Public recognition in a team meeting or internal email Additional time off (comp time) after the holidays Even small gestures show your team that their flexibility and dedication are valued, and that you see the extra effort. 6. Set Expectations With Clients (and With Your Team) If your operations will run on limited hours or staffing during the holidays, notify clients and partners well in advance. Clear communication avoids surprises and sets realistic expectations. Internally, define what’s essential versus what can wait, especially to avoid employees overworking during slower periods. When everyone understands what’s expected, your team can better prioritize, delegate, and breathe a little easier during the season. Final Thought: Flexibility Builds Loyalty The holiday season is a test of your workplace culture. How you support your team, especially when juggling competing needs, leaves a lasting impression. Even when saying no to a request, doing so with empathy and transparency reinforces a culture of trust, fairness, and respect. And in return, you'll see greater engagement, improved morale, and a team that’s ready to go the extra mile — during the holidays and beyond. Need help building better time-off workflows or updating your PTO policies before year-end? Simco’s HR and HCM experts are here to help. Let’s talk about how to balance compliance, efficiency, and employee satisfaction, all year round.

Have a question? Get in touch.