COBRA Premium Assistance Expiration Notice Deadline Approaching

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The COBRA premium assistance period, as part of the American Rescue Plan Act, will expire on September 30, 2021. Plans are required to send notices to assistance eligible individuals (AEIs) to inform them about the subsidy's expiration, which may occur on September 30, 2021, or earlier if the AEI reached the maximum COBRA coverage period before September 30, 2021. These notices must be sent at least 15 days but not more than 45 days before the AEI's COBRA subsidy expires. For AEIs whose subsidy period will end on September 30, 2021, notices must be sent by September 15, 2021.

The Employee Benefits Security Administration has released a model notice for the expiration of premium assistance. For more information on COBRA premium assistance, see the previous Benefits Notes blog post "IRS Releases Guidance on Premium Subsidies for Continuation Coverage under COBRA," and for more information about COBRA subsidy notices, see the previous Benefits Notes blog post "DOL's ARPA COBRA Subsidy Notices and FAQs: Stay Tuned for More."

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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