The American Rescue Plan Act (ARPA) COBRA premium assistance period runs from April 1, 2021, to September 30, 2021. The statute requires that plans provide a notice of expiration of the ARPA premium assistance (and available coverage options at that point) to all individuals who are receiving premium assistance during this time. Specifically, plans and issuers are required to provide individuals with a notice of expiration of periods of premium assistance explaining that the premium assistance for the individual will expire soon, the date of the expiration, that the individual may be eligible for coverage without any premium assistance through COBRA continuation coverage or coverage under a group health plan, and that coverage may be available through Medicaid or the Health Insurance Marketplace.

This notice must be provided 15 – 45 days before the individual’s premium assistance expires, so employers should be mindful of this requirement.

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