Title page

Contents

Highlights 2

Letter 5

Background 8

COBRA 8

COVID-19-Related COBRA Premium Subsidy 11

American Recovery and Reinvestment Act of 2009 (ARRA) COBRA Premium Subsidy 12

Agencies Implemented the COBRA Subsidy under a Tight Timeline; Selected Stakeholders Reported Some Challenges 13

EBSA and IRS Used Existing Processes to Implement the COBRA Subsidy, including Developing Guidance and Updating Systems 13

Selected Employers and Third-Party Administrators Identified Challenges Early in the Implementation Process Due to ARPA's Tight Timeline 21

More than 30,000 Employers Received $1.2 billion in Tax Credits for Providing COBRA Subsidies, but No Studies Have Been Conducted on the Effect of the Subsidy 23

Agency Comments 27

Appendix I: GAO Contact and Staff Acknowledgments 28

Table 1. Selected Digital Performance Metrics from Employee Benefits Security Administration's (EBSA) Consolidated Omnibus Budget Reconciliation Act of 1985... 17

Table 2. The Number of Employers That Received Tax Credits for providing Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) Subsidies to Eligible... 24

Table 3. The Amount of Tax Credits Employers Received for Providing Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) Subsidies to Eligible... 25

Figure 1. Estimated Total Number of Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) Enrollees, Calendar Years 2019-2022 10

Figure 2. Timeline of Selected EBSA and IRS Guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) Subsidy from March 11, 2021,... 14

Figure 3. Example of Advertisement Used in EBSA's Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA) Subsidy Marketing Campaign During the Pandemic 18