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COBRA Subsidy for MEWA

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I work with a MEWA and the association is questioning the 20 employee minimum for the COBRA subsidy.  Can someone point me in the direction of the reg that explains how the subsidy works with a MEWA?  If an employer that participates in the MEWA has fewer than 20 employees, do they still fall under the COBRA subsidy since they are part of the MEWA?


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The regs refer to "the person to whom premiums are payable", generally differentiating between insurers, multiemployer plans, and single employer plans, however they don't appear to directly address MEWAs.  I would think that it depends on whether the MEWA is the plan, or whether multiple plans participate in the MEWA to determine how the subsidy operates.  However, under Q&A15 of Notice 2021-31, the 20 employee minimum is directly related to COBRA coverage.  Presumably, the MEWA has already analyzed how COBRA applies generally, so the subsidy should apply in the same manner.

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