Reminder: COBRA Subsidy Expiration Date and Notice Requirement
The American Rescue Plan Act of 2021 (“ARPA”) requires group health plans subject to COBRA to provide a 100% COBRA premium subsidy and expanded enrollment rights to those who qualify as assistance eligible individuals (“AEIs”) for a period of six months (April 1, 2021, to September 30, 2021). ARPA also imposed new COBRA notice obligations on group health plans.
As the subsidy period nears the end, employers and plan administrators are required to provide a subsidy expiration notice (“Notice”) to AEIs, informing them of the impending subsidy termination.
