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.
Premium Collection in State Based Exchanges
Manatt Health Solutions
This issue brief, prepared by Manatt Health Solutions, summarizes federal policy guidance and outlines requirements, options and key considerations for State-based Exchanges (SBEs) on Exchange premium collection functionality. Exchanges organized pursuant to the Affordable Care Act (ACA) have certain requirements and several options for premium collection services for small businesses and individual consumers purchasing qualified health plans (QHPs) in 2014. While collection functionality is required in Small Business Health Options Program (SHOP) Exchanges, it is an optional service in the individual Exchanges. This brief explores the policy and operational considerations that SBEs face related to the three options for premium collections functionality:
■ The Exchange performs all premium billing and collections functions for SHOP and individual market consumers, with the option for people to pay their issuer directly, as required under the ACA;
■ The Exchange bills and collects the initial premium payment to effectuate real-time QHP enrollment; QHP issuers bill for all other months of enrollment; or,
■ The Exchange performs premium collection in the SHOP Exchange only, as required by law; QHP issuers perform the function for individual QHP enrollees.