The American Rescue Plan Act (ARPA) was signed into law on March 11, 2021 as a signature effort to assist in the recovery from the COVID-19 pandemic and the related economic downturn. Included as part of the sweeping legislation is a program to fully subsidize COBRA coverage for six months starting in April of 2021. This expert perspective provides a short overview of COBRA and mini-COBRA, the major elements of the ARPA COBRA Assistance program, and considerations for state policymakers related to the program.
Federal Requirements and State Flexibilities for Verifying Eligibility Criteria
Manatt Health Solutions – Deborah Bachrach and Kinda Serafi
The Affordable Care Act and the final Medicaid and Exchange regulations issued in March 2012 contemplate: real-time eligibility determinations; coordinated information technology eligibility systems across Insurance Affordability Programs; and, a simplified enrollment pathway for applicants that relies on electronic database verification coupled with self-attestation. States have a great deal of flexibility when establishing the income verification process for Medicaid/CHIP and the advance premium tax credits (APTC)/cost sharing reductions. This brief prepared by Manatt Health Solutions summarizes some of the key verification requirements, with an emphasis on financial eligibility. The chart in the brief summarizes federal requirements and areas for potential state flexibility when verifying eligibility for both Medicaid and APTCs.