After the passage of the American Rescue Plan Act (“ARPA”) on March 11, 2021, COBRA continuation coverage was subsidized 100% for many qualifying individuals. This subsidy took effect on April 1, 2021 and is set to expire on September 30, 2021. ARPA requires employers and plan sponsors to provide individuals with a notice 15-45 days prior to the expiration of the COBRA subsidy. Employers must notify participants no later than September 15, 2021. Employers and plan sponsors must also include information regarding when a participant’s subsidy will end, if they are eligible for coverage without any premium assistance through COBRA or a group health plan, and the total cost of the non-subsidized COBRA premium. The Department of Labor (“DOL”) has created a FAQ page for employers and plan sponsors here. In addition, DOL has also developed model notices which are available here.
Meredith S. Campbell
Chair Employment and Labor Group
Co-Chair Corporate Investigations, Governance & Risk Management
Email email@example.com T(301)255-0550