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SAG-AFTRA Health Plan Federal COBRA Subsidy ($0 COBRA Subsidy) FAQs

What is COBRA insurance?

COBRA stands for Consolidated Omnibus Budget Reconciliation Act of 1985. It's a federal law that gives individuals who lose their health coverage due to a Qualifying Event, such as job loss (other than voluntary) or hours reduction, the option to continue their coverage for a limited amount of time. For the SAG-AFTRA Health Plan, this includes people who lost coverage because they did not meet the earnings requirement.

For more COBRA information, see the program summary.

How long will the American Rescue Plan’s $0 COBRA subsidy be in effect?

The new COBRA subsidy ($0 COBRA subsidy) is available for periods of coverage starting April 1, 2021 and ending September 30, 2021. However, it will end earlier if your maximum period of coverage (generally, 18 months) ends earlier than September 30, 2021. It will also end earlier if you become eligible for coverage under another group health plan or Medicare. 

Note: If you become eligible for another group health plan or Medicare, you must notify the Plan. 


Eligibility

Who is eligible for the $0 COBRA subsidy?

Participants who do not meet or have not met the Health Plan’s covered earnings or days requirements are eligible for this subsidy. The $0 subsidy is for COBRA coverage beginning on or after April 1, 2021. In addition, family members who are no longer covered by the Health Plan because the participant did not meet the Health Plan’s covered earnings or days requirements may also be eligible for this subsidy. More information will be provided soon and eligible individuals will receive personalized notices explaining how the subsidy will be available to them. In the meantime, please log into Benefits Manager to make sure your information is up to date.
The temporary $0 COBRA subsidy is available to any participant (or family member) who, because the participant did not meet the Health Plan’s covered earnings or days requirements:

  • Is enrolled in COBRA, or becomes eligible for COBRA, on or after April 1, 2021, and before the subsidy ends on September 30, 2021; or
  • Became eligible for COBRA on or after November 1, 2019, such that the period of COBRA coverage to which they would be entitled (18 months) includes any month between April and September of 2021—even if the individual did not elect COBRA when it was initially offered or elected COBRA but discontinued it before April 1, 2021. In most cases, this means the participant was no longer eligible for the Health Plan as early as January 1, 2020.

Who is not eligible for the $0 COBRA subsidy?

The $0 COBRA subsidy is not available when:

  • COBRA is triggered by other qualifying events (e.g., death, divorce or dependent child aging out).
  • You are eligible for coverage under any other group health plan (including coverage as a dependent under your spouse or parent’s other group health plan).
  • You are eligible for Medicare.
  • Your loss of coverage was not based on a reduction in hours or involuntary termination.

We expect additional guidance from the federal government regarding who is and is not eligible for the subsidy.

Are my family members eligible for the $0 COBRA subsidy?

Yes, if the participant loses coverage due to a reduction in hours or involuntary termination (including not meeting the earnings or days requirements), also called a Qualifying Event, any family member covered prior to that Qualifying Event who also lost coverage when the participant did may be eligible for the federal COBRA subsidy. In order to receive the federal subsidy, the individual cannot be eligible for Medicare or other group coverage.

Will the $0 COBRA subsidy be available to me if I am going on COBRA starting April 1, 2021?

Yes, the $0 COBRA subsidy will be available to assist eligible individuals for coverage beginning April 1.

I already received a COBRA offer for April 1, 2021. Will I receive a new offer that shows the subsidy?

Yes. You will receive a request for treatment as an Assistance Eligible Individual form to fill out.

I elected COBRA due to a reduction in hours or involuntary termination before April 1, 2021 but discontinued it. Am I eligible to resume COBRA now and receive the subsidy?

Yes, if you are not eligible for other group health coverage or Medicare.

I was offered COBRA due to a reduction in hours or involuntary termination before April 1, 2021, but I did not take it at that time. Am I eligible for the subsidy now?

Yes, if you are not eligible for other group health coverage or Medicare.

I elected COBRA due to reduction in hours or involuntary termination before April 1, 2021, but discontinued it. Am I eligible to resume COBRA now and receive the subsidy?

Yes, if you are not eligible for other group health coverage or Medicare.

Are Medicare-Eligible participants including Senior Performers who lost or are losing Active coverage before April 1, 2021, eligible for the $0 COBRA subsidy?

No. Individuals who are eligible for Medicare cannot get the subsidy. However, if you are Medicare-eligible and enrolled in the Temporary COBRA Relief or Extended Career COBRA program, reduced premiums will continue.

I am a Medicare-Eligible non-Senior Performer. I do not have sufficient health credits to qualify for medical coverage. Am I eligible for the $0 COBRA subsidy?

No. Individuals who are eligible for Medicare do not qualify for the subsidy.

I expect to receive a COBRA offer due to a reduction in hours or involuntary termination on July 1, 2021. Am I eligible for the $0 COBRA subsidy?

Yes. If you are not eligible for other group health coverage or Medicare, you are eligible to receive the subsidy until September 30, 2021. After that, you will have to pay regular COBRA rates in order to continue your coverage.

I lost coverage before April 1, 2021, received a COBRA offer and did not enroll in COBRA at the time of the offer. I subsequently became eligible for Active coverage, but again, did not enroll at that time. Am I eligible for the $0 COBRA subsidy now?

No.

I lost coverage the end of 2019 because I didn’t meet the earnings requirement due to a reduction in hours or involuntary termination. I was mailed a COBRA offer for January 1, 2020. I didn’t enroll at the time. Am I eligible for the $0 COBRA subsidy now?

Yes, however, you aren’t eligible for the full 6 months. You’re only eligible for the months that you continue to be eligible for COBRA. In other words, you are eligible for the $0 COBRA subsidy if you were no longer eligible for the Health Plan starting January 1, 2020. Since you are only eligible for a maximum of 18 months of COBRA continuation coverage (measured from your loss of coverage starting January 2020), you will only be eligible to receive the subsidy for the months of April, May and June 2021. June is your 18th month of COBRA continuation coverage. You will receive a notice from the Plan regarding the expiration of your COBRA period and the subsidy in May.

I lost coverage in March 2019 because I did not meet the earnings requirement. I was mailed a COBRA offer for April 1, 2019. I did not enroll at the time of the offer. Am I eligible for the $0 COBRA subsidy now?

No. A typical COBRA coverage period is 18 months. To be eligible for the $0 COBRA subsidy, you would’ve had to be eligible for COBRA due to a reduction in hours or involuntary termination on or after November 1, 2019.

If I am already on the Temporary COBRA Relief Program with the Plan, can I switch to the $0 COBRA subsidy? What do I need to do to switch?

Yes. If you are already on the Plan’s Temporary COBRA Relief Program or Extended Career COBRA and you are eligible for the $0 COBRA subsidy, the Temporary COBRA Relief Program or the Extended Career COBRA will be suspended during the time you are eligible for the 100% federal subsidy.

That means that you will pay $0 of COBRA premiums during the federal subsidy period. Once you are no longer eligible for the federal subsidy, you will again be eligible for the Plan’s subsidy programs, if you have any time left in your COBRA period. More information on how this process and switch will work will be available once the federal government provides additional guidance.

Medicare-eligible individuals are not eligible for the $0 COBRA subsidy but the Plan will continue to provide the Temporary COBRA Relief Subsidy to eligible individuals until the end of their subsidy period.

I am on COBRA now due to reduction in hours or involuntary termination, but my period ends before September 30, 2021. Will I be eligible for the $0 COBRA subsidy?

Yes. The subsidy period ends September 30, 2021. If you are still eligible for COBRA after April 1, 2021, you may be eligible to receive the $0 COBRA subsidy for the remaining months of your COBRA coverage.

I’m eligible for group health coverage through my spouse’s employer, but I am not enrolled. Does this mean I am not eligible for the $0 COBRA subsidy?

Yes, this does mean you are not eligible for the $0 COBRA subsidy since you are eligible for other group health coverage. Eligibility for excepted benefits (such as limited-scope dental or vision coverage), a health flexible spending arrangement or a qualified small employer health reimbursement arrangement would not terminate subsidy eligibility.

My spouse has group coverage but I am not currently covered under my spouse’s plan even though I am eligible for coverage under the plan as a dependent. Am I eligible for the $0 COBRA subsidy?

No, individuals eligible for coverage under another group health plan are not eligible for the $0 COBRA subsidy.

I am currently covered by an ACA plan. Can I disenroll from my ACA plan and elect the $0 COBRA subsidy?

Yes. You may be eligible for a special enrollment period in the ACA Marketplace when the subsidy ends.


Enrollment and Premiums

I am already enrolled in COBRA. How do I enroll for the $0 COBRA subsidy?

If you lost coverage due to a reduction in hours or involuntary termination, have at least a month of COBRA available as of April 1, 2021 and are already enrolled in COBRA, the Plan has not charged you for your April premium. You will receive the special enrollment materials in mid- April. You must complete and return the request for treatment as an Assistance Eligible Individual form and not be eligible for other group health plan coverage in order to continue in the $0 COBRA premium program.

I am not currently enrolled in COBRA. How do I enroll for the $0 COBRA subsidy?

If you lost coverage due to a reduction in hours or involuntary termination, have at least a month of COBRA available as of April 1, 2021 and are not already enrolled in COBRA you can pre-enroll in the $0 premium COBRA on Benefits Manager beginning April 9. You will also receive and must complete and return the request for treatment as an Assistance Eligible Individual form and not be eligible for other group health plan coverage in order to continue in the $0 COBRA premium program.

When I fill out the special enrollment forms for the $0 COBRA subsidy, will I be required to validate my eligibility or make any attestation?

You will receive an election form and request for treatment as an Assistance Eligible Individual form to fill out. You must follow the instructions and return the required information. If you are not eligible for the $0 COBRA subsidy per the criteria defined in the American Rescue Plan Act, you will be charged a full COBRA premium or Temporary COBRA Relief or Extended Career COBRA premium, depending on what you qualify for.

I am not eligible for the federal COBRA subsidy because I am eligible for other insurance. I also currently pay the Temporary COBRA Subsidy from the Plan. Can I enroll just my federal subsidy-eligible family members in the federal COBRA subsidy program?

Yes. Please contact the Plan.

I am over 65 and eligible for Medicare, but do not qualify for the Senior Performers HRA Plan. I have two dependents who are eligible for the federal COBRA subsidy. What is my premium and how can I enroll?

The current guidance from the federal government says your dependents will pay $0 premium for COBRA. Since you are not eligible for the federal COBRA subsidy, you will have an option to enroll in regular COBRA (or Temporary COBRA Relief, if qualified) and may be responsible for paying your COBRA premium back to the date of your initial COBRA offer. We are still waiting for additional guidance from the federal government and will have more information about enrollment and specific premiums in mid-April. Please contact the plan at that time.

I lost coverage January 1, 2021 and I am eligible for the federal COBRA subsidy. My spouse is not eligible for the federal COBRA subsidy. Can my spouse still enroll in COBRA effective April 1, 2021?

You can enroll in the federal COBRA subsidy program beginning April 1, 2021 but your spouse may have to pay the full COBRA premium back to January 1, 2021 when you initially lost coverage.

I lost coverage January 1, 2020 and received a COBRA offer, never enrolled, but I am not eligible for the federal COBRA subsidy. Can I still enroll in COBRA?

You can still enroll in COBRA and pay the regular COBRA subsidy, but you may have to pay for coverage back to January 1, 2020 when you initially lost coverage.

Will my COBRA coverage really be free?

During the six-month period from April through September of 2021, participants (and family members) who are eligible for COBRA during that period and who qualify for the federal subsidy will pay $0 of the monthly COBRA premium. The Plan will charge participants and dependents $0 for COBRA and will bill the federal government for the COBRA premiums.


Covered Benefits

What benefits are covered under the $0 COBRA subsidy?

The COBRA subsidy is related to cost, not benefits. The benefits covered under the $0 COBRA subsidy are the same as those covered under regular, non-subsidized COBRA. 

Does $0 COBRA coverage include Rx, dental, vision and life insurance?

The $0 COBRA coverage will include Rx, dental and vision if you were enrolled in these benefits at the time of your COBRA Qualifying Event (your reduction in hours or involuntary termination that caused a loss of eligible for coverage). Life insurance is not included in COBRA.


COBRA Payments

How do I pay my COBRA premium?

You have different options for paying your COBRA premiums, as detailed here.

I am currently enrolled in COBRA. How do I get the $0 COBRA subsidy?

The Plan has not charged you your April premium but has extended your coverage contingent on you completing the enrollment process. You will receive a notice and some forms to fill out from the Plan. You must follow the instructions and return the required information. After the Plan reviews the information, you have submitted, if you are determined to be eligible for the subsidy, it will continue to be automatically applied. If you have already paid any COBRA premium payments for any months for which you are determined to be eligible for the subsidy, those premium payments will be returned to you.

I already made COBRA payments for April. How will I receive the refund?

You will receive a notice and some forms to fill out from the Plan. You must follow the instructions and return the required information. The Plan will review the information you have submitted and determine if you are eligible for the $0 subsidy for the premium payments that you already made. If you are eligible, those premium payments will be returned to you.


When COBRA subsidy ends

How long does the $0 COBRA subsidy last?

The subsidy will last for six months at most, from April 1, 2021, through September 30, 2021. The subsidy will end earlier if your maximum period of COBRA coverage (generally, 18 months) ends earlier than September 30, 2021. It will also end earlier if you become eligible for coverage under another group health plan or Medicare. You are required to notify the Health Plan if you become eligible for such coverage and would be subject to penalty if you fail to do so.

What happens when the $0 COBRA subsidy ends on September 30, 2021?

You will receive a notice with additional information from the Plan. It is possible that Congress could extend the subsidy. The Plan will receive a notice regarding the expiration of the subsidy on or before April 25. But if that doesn’t happen, and you are still eligible for COBRA, you can pay the full cost of COBRA to continue the coverage after September. Alternatively, you can enroll in health coverage through the Affordable Care Act (ACA) Marketplace. For information, healthcare.gov.

Note: You have until May 15, 2021 to sign up for an ACA-compliant health plan. The new law increases subsidies for these plans, which will reduce costs for many who enroll in them.

Note: The extension of the above deadlines does not extend the maximum period of COBRA coverage to which you are entitled.


For more information

For the exact dates that will apply to your COBRA period, please log into your Benefits Manager.  

Want to review the COBRA Premium Subsidy from the Department of Labor?