The American Rescue Plan Act (ARPA) requires a 100% COBRA premium subsidy for certain individuals entitled to COBRA or state continuation coverage due to reduction of hours or involuntary termination of employment. To be eligible for the subsidy, the COBRA qualified beneficiary must have a qualifying event that is a reduction in hours or involuntary termination of employment, elect COBRA, elect to be considered an assistance-eligible individual, and not be eligible for other group health coverage or Medicare. Subsidized coverage may be available to an assistance-eligible individual from April 1, 2021 through September 31, 2021. See our prior article which may be accessed by clicking here.
The Department of Labor requires health plans to notify individuals of their ARPA COBRA subsidy options and obligations. One of these required notifications is to provide notice of the expiration of subsidized coverage. Assistance-eligible individuals must be notified about the end of their premium subsidy no less than 15 days and no more than 45 days prior to the subsidy ending.
As the maximum subsidy period is ending September 30, 2021, plans must make sure to distribute the required end of subsidy notice between August 16 and September 15, 2021. For employers who use BAS’ Cobra Control Services for continuation of coverage processing, CCS will send the required notice within the prescribed time frames.
