COBRA Subsidy Notice Due by Sept. 15 (Sooner for Some)


The COBRA subsidy period under the American Rescue Plan Act (ARPA) is approaching its end date. ARPA provided a 100% subsidy of premiums for employer-sponsored group health insurance continued under COBRA between April 1 and September 30, 2021 (which you can read more about here).

Employers and health plan administrations are required to provide subsidy termination notices to all COBRA qualified beneficiary who became eligible for COBRA (eligibility detailed here). This notice must be furnished anywhere between 15-45 days before the subsidy will end for that Individual.

Because the end date for COBRA subsidies are September 30th, the notices must be sent by September 15 at the latest to eligible individuals. The notice must include:

  • The statement that the COBRA subsidy will end soon with the end date (September 30th) featured prominently on the document; and
  • The statement that the individual may be eligible for health insurance coverage through COBRA still (without the subsidy, of course) or through another group health plan.

Please see a link to the model notice that the Department of Labor published, and take a free copy of our Compliance Overview for your company’s reference.

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