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Premium Assistance Expiration Notices Due as End of COBRA Subsidy Period Approaches



With the COBRA subsidy period set to end on September 30, 2021, the deadline is fast approaching for plan administrators to distribute notices alerting assistance eligible individuals (AEIs) of the subsidy’s expiration. Plans are required to send a notice 15 to 45 days before an AEI’s subsidy ends due to the expiration of the AEI’s maximum COBRA coverage period (generally 18 months) or the end of the subsidy period on September 30, 2021 (see our Checkpoint article). For AEIs whose subsidy period will end on September 30, notices must be sent no later than September 15. The notice must describe (1) the subsidy expiration date; (2) the right to continue COBRA coverage without the subsidy for the remainder of the individual’s maximum coverage period (if applicable); and (3) other coverage options that may be available. Earlier this year, the DOL issued this model notice that may be used to draft notices for a plan’s AEIs (see our Checkpoint article).

EBIA Comment: Plan administrators that have not already distributed expiration notices to AEIs affected by the subsidy’s end have just under two weeks to comply. For more information, see EBIA’s COBRA manual at Section VI.H (“ARPA Premium Subsidy”) and the manual’s filled-in Sample Notice of Expiration of Period of Premium Assistance that illustrates the use of the DOL’s model notice by a group health plan.

Contributing Editors: EBIA Staff.

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