COBRA notices and election forms are required to go out to assistance eligible individuals by May 31. Under the American Rescue Plan Act (“ARPA”), not only is COBRA subsidized for certain recipients but employers are also required to provide new and updated notice and election forms. Those notice and election forms must be sent no later than May 31. There is still time to timely complete the process. Failure to provide the appropriate notice and election forms timely could result in penalties and other financial liabilities. Below are links to the new guidance, previously issued FAQs, model notices, and our previous, more detailed summaries. 

https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/cobra/premium-subsidy

https://www.clarkhill.com/news-events/news/april-1-brings-major-cobra-changes-under-arpa/

https://www.clarkhill.com/news-events/news/new-cobra-notices-must-be-issued-by-may-31/