September 13, 2021

Important Notice – Upcoming Notice Deadline for COBRA Subsidies

The deadline to send a new COBRA notice required under the American Rescue Plan Act of 2021 (“ARPA”) is approaching quickly. Employers and COBRA administrators will need to send those notices no later than September 15, 2021, to satisfy that obligation.

Under ARPA, an assistance eligible individual (“AEI”), which is a COBRA qualified beneficiary who becomes eligible for COBRA due to a reduction in hours or involuntary termination of employment, may be eligible for a COBRA subsidy equal to the entire COBRA premium for the period from April 1, 2021 through September 30, 2021. 

Employers and plan administrators are required to provide subsidy termination notices to AEIs between Monday, August 16, 2021, and Wednesday, September 15, 2021, to satisfy the 15-to-45 day Notice window. The subsidy termination notices must include the following information:

  • A statement that the COBRA subsidy will end soon and “prominent identification” of the date that it will end; and
  • A statement that the individual may be eligible for coverage without a COBRA subsidy through COBRA or another group health plan.

For groups who utilize a COBRA administrator, your Administrator should be providing these notices to AEIs.  For groups who administer COBRA internally, the Department of Labor (“DOL”) has provided a model notice and although not required to be used, the DOL considers its use as good faith compliance with the notice requirements under ARPA. 

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