The Trade Preferences Extension Act of 2015 included the return of the Health Coverage Tax Credit (HCTC). The HCTC had previously expired on December 31, 2013 along with the start of the availability of individual policies through the Health Insurance Marketplace. The HCTC, which is now set to expire on December 31, 2019, is a tax credit that can be used by qualified individuals in order to pay for COBRA or individual coverage after they lose employment due to foreign competition. Since this is a tax credit for the individual, employers are not involved in the management or use of this credit. However, since it can affect whether a participant choses to elect coverage under COBRA, it is important to include information about HCTC as part of the COBRA Rights information in the Election Notice. This language was removed from the DOL model Election Notice in 2014 and we expect it will be added back shortly.
For an updated COBRA forms kit, please contact your Keller account team.