ARPA provides free COBRA coverage to Assistance Eligible Individuals (AEIs) who lost or who lose healthcare coverage due to a reduction in hours or involuntary termination.
Employers must notify AEIs about the expiration of their subsidy, the date of expiration, and that they may be eligible for coverage without the subsidy through COBRA or another group health plan.
Subsidy Period Expiration Notice
ARPA requires subsidy expiration notices to be sent to Assistance Eligible Individuals (“AEIs”) prior to the expiration of the Subsidy Period. Notice must be provided to AEIs whose subsidy is going to expire, unless the expiration is due to the AEI becoming eligible for coverage under another group health plan. This Expiration Notice should be sent no more than 45 days and no less than 15 days prior to the expiration of the Subsidy Period. The Expiration Notice should advise of the date the Subsidy is to expire, and a statement that the individual may be eligible for coverage without premium assistance through COBRA continuation coverage or under a group health plan.
This notice is not required for instances in which the loss of the Subsidy is due to the AEI becoming eligible for other group coverage or the maximum COBRA eligibility period ends prior to September 30, 2021.
The Department of Labor (DOL) has provided a Model Notice of Expiration of Period of Premium Assistance that employers can use to fulfill this requirement.