The American Rescue Plan will be signed into law tomorrow. That is only the conclusion of the first phase of policy making — getting agreement among relevant stakeholders to change policy and allocate resources. The second phase has already started behind the scenes and it will become increasingly important in the next several weeks. Implementation of what Congress thinks it authorized and appropriated is the next, critical phase.
The ARP is a big law with many moving parts with very fast implementation challenges.
The subsidies increases and subsidy cliff elimination are exciting and will make a huge difference to people in the next 4-6 weeks.
But what we need now, not tomorrow and not next week, is clarification on the COBRA section.
I’m flying the white flag here. Anybody know? https://t.co/Y7UJlIKn0G
— Jenny Chumbley Hogue (@kgmom219) March 11, 2021
Jenny Hogue is an insurance broker and a fellow ACA nerd. She is identifying a real need. ARP will have the federal government pay 100% of COBRA premiums from April 1, 2021 to September 30, 2021. This is what Congress has said it will do.
The first set of questions are who gets the money, how does the money arrive and when does it start flowing? Does the money go direct to insurers? Does the money go to individuals to reimburse payment? Does the money go out this week or does it first go out in mid-April? Is it direct deposited? Is it a check? The second set of questions is how does the money flow to people already on COBRA and paying full premium? Is that a different pathway than people who are not on COBRA now but will be on COBRA in June?
There are a lot more questions to ask which need to be answered.
These are critical implementation questions on a single, specific component of a very big law. Implementation will be critical on the political valence and salience of the law. A well implemented law will have a different political value than a complete clusterfuck of an implementation.