COBRA Premium Assistance Period Ends September 30, 2021

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Epstein Becker & Green

On September 30, 2021, the COBRA premium assistance period established by the American Rescue Plan Act (“ARPA”) will come to an end. ARPA requires, among other things, that employers provide 100 percent COBRA premium subsidies to assistance eligible individuals (“AEIs”) and their qualified beneficiaries, if they are eligible for COBRA during the six-month period beginning April 1, 2021 through September 30, 2021. Employers must notify all AEIs that their subsidy period is going to end by sending the Notice of Expiration of Premium Assistance at least 15 days, but no more than 45 days, before the expiration of the premium assistance. With the COBRA premium assistance period less than two weeks away, employers should have already sent their final Notices of Expiration. Employers that have not done so, however, should send the notices now.

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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