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Employment Law

COBRA Subsidies End September 30

COBRA subsidies under the American Rescue Plan Act of 2021 (ARPA) end on Sept. 30, 2021, which means businesses must send expiration notices to former employees and other eligible individuals whose COBRA premiums have been covered by the subsidy.
To the extent you have a third-party administrating your COBRA benefits, you might want to make sure that such plan administrator notifies assistance-eligible individuals (AEIs) at least 15 days (but no more than 45 days) before they will lose their COBRA subsidy. Otherwise, if you handle COBRA benefits yourself, you will need to make this notification. Please note that this does not mean they will lose their COBRA coverage; it just means they have to start paying for it on their own. For AEIs whose subsidies will expire on Sept. 30, 2021, notices must be sent between Aug. 16 and Sept. 15, 2021.
Subsidy expiration notices must, at a minimum, include the following information:
  • A prominent identification of the date the subsidy will expire.
  • A statement that the AEI may be eligible for coverage without a subsidy through COBRA or coverage under a group health plan.
Please see the United States Department of Labor model notice here. If you have any questions, please contact Bob Lepp at 402-492-9200 or

Fri Sep 10, 12:58pm

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