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Deadline Approaching for COBRA Subsidy Final Notice

COBRA subsidies under the American Rescue Plan Act (ARPA) are set to expire on September 30th. Plan administrators must provide individuals covered under COBRA between April 1, 2021 and September 30, 2021 with a Notice of Expiration of Period of Premium Assistance no later than 15 days before his or her COBRA premium subsidy period expires. For any such individual whose COBRA premium subsidy period will end on Thursday, September 30, 2021, the Notice of Expiration must be furnished no later than Wednesday, September 15, 2021. The COBRA continuant’s premium assistance generally terminates with the first month beginning on or after the earliest of (1) September 30, 2021, (2) the expiration of the maximum required COBRA period for the COBRA continuant, or (3) the date that the COBRA recipient becomes eligible under another group health plan or for Medicare benefits. A model expiration notice from the Department of Labor, “Notice of Expiration of Premium Assistance” can be found here. Editor’s Note: We will be offering a 3-hour webinar, “Legislative Update” on Tuesday, September 14th from 9-12. To register, contact Jessenia Narvaez at jessenianarvaez@robertnoonan.com or

(860) 349-7010.