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Pinpointing COBRA responsibility during a business reorganization requires careful advanced consideration of numerous fact-specific elements.(Photo: Shutterstock)

The American Rescue Plan Act’s (ARPA) federally funded, 100 percent “free” COBRA subsidy has generated much attention — and perhaps even more questions. Fortunately, although we still await further federal agency guidance to resolve lingering concerns, we can sort out many questions with already available published material. One such issue relates to subsidy responsibilities that surface in conjunction with a business reorganization.

Dennis Fiszer is chief compliance officer and senior vice president for global insurance brokerage Hub International, provides compliance and consulting services regarding health plans and other employee benefits. His areas of expertise include all aspects of ACA, including employer reporting, hours tracking, transition relief, and plan valuations for affordability and minimum essential coverage analysis. 

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