Communicating Assistance Eligible Individuals (AEIs) to COBRA

For our Namely Managed Benefits clients: updates on reporting Assistance Eligible Individuals (AEIs) to your COBRA vendor.

Overview

If you are a Namely Managed Benefits client, please be advised:

Under the American Rescue Plan Act of 2021 (ARPA), COBRA Qualified Beneficiaries who may qualify as Assistance Eligible Individuals (AEIs) must be notified of their status and provided with corresponding information on the COBRA subsidy process. 

As a reminder, AEIs are people who were terminated involuntarily or lost coverage due to a reduction in hours.  Exceptions- i.e., ineligible individuals- would be employees who were terminated for gross misconduct or those who lost coverage as a result of divorce or aging out of the plan. 

We have been given guidance from numerous COBRA vendors that the ongoing AEI eligibility status will be a manual process and cannot be communicated via a COBRA file feed.

Your Managed Benefits Team Is Ready to Help

Going forward, clients must notify their Namely Managed Benefits team for terminations or reductions in hours that result in an eligible AEI status for the individual. Note: no action would be needed if the individual is ineligible for the subsidy—see below for more details on termination reasons that would make an employee ineligible.

In order to complete this on your behalf, we must have the request in writing for record-keeping, auditing, and compliance purposes. Once notified, your Namely Managed Benefits team will update the AEI status with your COBRA vendor.  

AEI Eligible Reasons

Below are the reasons for which you must notify your Namely Managed Benefits team of AEI status:

  • Laid Off

  • Reduction in Force

  • Termination for Cause

  • Reduction in Hours

  • Other

If employees are terminated for any other reason (e.g., Resignation, Retired, Gross Misconduct), clients are not required to notify Namely, as these would not merit AEI status. 

AEI Subsidy Details

AEIs are entitled to a 100% COBRA subsidy for medical, dental, and vision coverage for the time period of 4/1/21 through 9/30/21.  This subsidy will end prior to 9/30/21 if the member becomes eligible for coverage through another employer or the member becomes eligible for Medicare. 

If you have any questions on the information above or your COBRA status as an employer, please reach out to your Namely Benefits Consultant for assistance.