DOL Issues Model Notices to Aid Employers in Their Compliance Obligations Under ARPA’s COBRA Subsidy Provision
One of the provisions in the American Rescue Plan Act of 2021 (ARPA) includes a 100% fully subsidized COBRA premium for certain individuals beginning on April 1, 2021 and ending on September 30, 2021 (subsidy period). Employers must timely notify individuals who become entitled to elect COBRA during the subsidy period of the subsidy’s availability and the option to enroll in different coverage (if permitted by the plan) by May 30, 2021. In addition, employers must notify individuals of their subsidy’s expiration between 45 and 15 days before the expiration date.