American Rescue Plan Act: COBRA Subsidy Timeline and Forms
Following is a timeline and link to forms to assist in administration of the COBRA notices that must be sent to comply with the American Rescue Plan Act (ARPA).
DATES:
- March 11th, 2021: American Rescue Act signed by President Biden.
- April 1st, 2021: Cobra Subsidy is effective
- April 8th, 2021: Department of Labor releases model COBRA Notices
- May 31st, 2021: Last day in which COBRA notices can be mailed by employers (60 days from effective date)
- April 1st through September 30th:
1) 60-days from initial notices the election period ends for eligible individual.
2) Mailing of the Premium Assistance Expiration Notice required 15-45 days prior to the end of the premium subsidy.
- September 30th, 2021: Expiration of Subsidy
FORMS:
Summary of COBRA Premium Assistance Provision Summary: Should be sent with all COBRA notices – APPENDIX TO § 2590 (dol.gov)
Model Notice for Fully insured groups with State continuation: Model Alternative Notice of ARP Continuation Coverage Election Notice (dol.gov)
Model Notice for Groups covered under Federal regulations: Model COBRA Continuation Coverage Election Notice (dol.gov)
Model notice for New COBRA events between April 1st and September 30th, 2021: Model COBRA Continuation Coverage Election Notice (dol.gov)
Model Notice for Expiration of Premium Assistance: Notice of Expiration of Period of Premium Assistance (dol.gov)
DOL Link with MS Word versions available: COBRA Premium Subsidy | U.S. Department of Labor (dol.gov)