OCA remains committed to being transparent and keeping our clients informed on all of the ARPA COBRA subsidy news. 

We have provided our latest ARPA operational update below as well as launching our COBRA subsidy FAQ page. We will continue adding helpful Q&As as our open questions become clearer and additional guidance is issued. 

OCA's ARPA Operational Update (Week of March 28th):
 
Step 1 - Identifying Assistance Eligible Individuals (AEI)
 
Update: Completed on 3/24/21
 
OCA has completed its list of potentially eligible individuals for the subsidy. As we previously communicated, this was the first challenge we faced. Historically, the industry did not track voluntary vs. involuntary terminations. OCA's goal is to be proactive by taking a two prong approach. First, by confirming with employers/brokers the AEI list and then reaffirming eligibility when we issue the special election notice to the AEI. Click here to see the definition of an AEI
 
Step 2 - Communicating List to Employers/Brokers
 
Expected Start/End Date: 4/5/21 through 4/15/21

OCA plans to begin emailing each employer and/or broker the list of their potentially eligible AEIs. This will begin the week of April 5th. Thousands of clients will need to be notified, so we expect the communication to be completed no later than April 15th. The email will include an excel attachment listing each employers potentially eligible AEIs. Clients will be asked to update the file by validating the AEIs "termination type." To view a sample of the excel file, please click here

If OCA does not hear from the employer/broker prior to OCA mailing the special election notice (TBD), OCA will assume the termed employee was involuntary terminated, resulting in the AEI receiving the special election notice.

When Will Notices Be Sent to AEI?
 
OCA will be mailing out a special election notice to eligible individuals with the understanding that:
    • ARPA calls for the Department of Labor to issue model notices within 30 days of the enactment and it is very likely OCA will wait for the DOL to issue the model notice before mailing out the special election notice to eligible individuals.
    • ARPA states that the special election notice must go out within 60 days of April 1st.
    • Eligible individuals will then have 60 days after the date on which the special notice is provided, with the subsidy going back to April 1st.
    • Please note that a special per notice fee will apply.
 
What's Next?

OCA will be hosting a webinar with Ashley Gillihan of Alston & Bird on Thursday, April 1st at 2PM to review ARPA in more detail. To register, 
please click here.
 
OCA will continue to keep you up to date and set expectations for what the next couple of months could look like. We will be back to you again with additional information and resources.