You may recall that under the American Rescue Plan Act of 2021 (ARPA), group health plans that are subject to COBRA must provide coverage to assist eligible individuals (AEI) at no cost between April 1, 2021, and September 30, 2021 (the Subsidy Period). In addition, plan sponsors must notify affected AEIs within a window (45 to 15 days) before the premium assistance will end. So, plan sponsors must issue notices to AEI’s whose continuation coverage runs through September 30 no later than next Wednesday, September 15, 2021.
Plan sponsors may create their own notice, but the Department of Labor has provided a model notice that can be used.
If an AEI is eligible to continue COBRA coverage beyond September 30th, they will be required to pay the normal COBRA premium for that extended coverage. The notice should include this information.
Employers take-away: If you have not already determined who is entitled to this notice, created your own notice, or copied the DOL model notice, you don’t have much time left.