Last Update On 4/7/2021

What is the ARPA COBRA Subsidy?

The ARPA COBRA subsidy allows for certain Assistance Eligible Individuals (AEI) to receive a subsidy for COBRA coverage between April 1, 2021 and September 30, 2021. This allows for the following:

  • 100% COBRA subsidy for the period of April 1, 2021 to September 30, 2021.
  • Qualified Beneficiaries (QB) that did not previously elect COBRA, or previously elected COBRA, but are still in their 18-month window of COBRA eligibility can elect to start coverage, provided they are Assistance Eligible Individuals.


Who is qualified? 

The ARPA Subsidy applies to Assistance Eligible Individuals (AEI). To qualify, a participant must meet and attest to all the following criteria:

Qualified Beneficiaries (QB) with a COBRA event type of Involuntary Termination of Employment or Reduction in Hours, including qualified dependents (spouse or children) covered at the time of the initial Qualified Event.

The QB must not be eligible for any other disqualifying medical coverage. Note, merely being eligible for (not actually covered by) means the subsidy is not available. Disqualifying coverage includes:

  • Any group health plan (such a new employer plan or a spouse’s plan)
  • Medicare
  • A health FSA
  • A Qualified Small Employer Health Reimbursement Arrangement (QSEHRA)


When will I be able to claim the subsidy?

Vita is currently developing the necessary systems capability to accommodate this new provision. The target date to send out formal notices to Assistance Eligible Individuals is the second week in May. At this time, Assistance Eligible Individuals will be able to make a coverage election or apply the subsidy to existing COBRA coverage. The notice will contain detailed instructions and AEIs will have 60 days from the date the notice is provided to the individual.

What do I need to do to receive the subsidy?

The communication in May will contain detailed instructions regarding how to receive the subsidy. Additionally, Vita will continue to update this Frequently Asked Questions document, as necessary.

What plans qualify?

The subsidy applies to Medical, Dental, Vision, and Employee Assistance Programs (EAP). The subsidy applies only to plans that were in force at the time of the Qualifying Event.

Is this subsidy taxable to me?

The subsidy is not taxable to the beneficiary.

Can I start new coverage effective April 1st? 

Yes. Even if COBRA coverage was not elected previously or coverage was elected and has since been terminated, Assistance Eligible Individuals can re-elect under this law effective April 1, 2021.

Do I need to make my April payment? 

Yes. If you are currently on COBRA and are an Assistance Eligible Individual, please continue to make regular payments in order to avoid termination of coverage. If you are an AEI, Vita will reach out to confirm eligibility and, at that time, either issue a refund or credit your account against future month’s premiums (if COBRA coverage will continue beyond the subsidy period).

How will communication be sent? 

Notices will be sent to the mailing address in the Vita Member Portal.