COMPLIANCE ALERT: ARPA COBRA Subsidies Ending Soon

The COBRA subsidies under the American Rescue Plan Act (ARPA) will expire September 30, 2021. An eligible individual was able to receive the COBRA subsidy until September 30, 2021, the end of their maximum COBRA period or until they became eligible for another group health plan or Medicare.

ARPA requires subsidy recipients obtain a notice of expiration of the subsidy a minimum of 15 days prior to the expiration date, but no more than 45 days prior.

This means all recipients receiving subsidies will expire September 30, 2021, and must have this notice between August 15, 2021, and September 15, 2021. If this person’s COBRA subsidy ends before September 30 because their maximum COBRA period is ending, then the notice also must be provided at least 15 days (but not more than 45 days) before the expiration date.

Note: if a person’s COBRA subsidy ends because they are now eligible for coverage under a group health plan or Medicare, the notice is not required.

Link to Department of Labor Notice is found below.