Reminder: Notices Required For the End of COBRA Premium Assistance

August 16, 2021

The American Rescue Plan Act of 2021 (“ARPA”) made COBRA premium assistance available to certain assistance eligible individuals during the period from April 1, 2021 to September 30, 2021.  ARPA also included new notice obligations that were imposed on employers and plan administrators, including a notice of expiration that must be provided no sooner than 45 days and no later than 15 days before the expiration of the COBRA premium assistance period under ARPA.

A summary of the law and regulatory guidance is contained in our prior alerts (available here, here, and here).  Assistance eligible individuals whose COBRA premium assistance is expiring on September 30, 2021 must be provided with a notice of expiration of premium assistance meeting specific requirements under ARPA between August 16, 2021 and September 15, 2021.  The Department of Labor has published a model notice that employers and plan administrators may use for this purpose (link provided below).

Model Notice of Expiration of Premium Assistance: MS Word PDF.

Also available in Spanish MS Word PDF.

To view a PDF of this alert, please click here.