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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). 


  • 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


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) 

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