The 100-percent premium subsidy for eligible COBRA health care enrollees, enacted earlier this year as part of the American Rescue Plan Act (ARPA), period is ending September 30, 2021.

Group health plans need to send an expiration notice to eligible individuals 15 to 45 days before their premium assistance expires. The last day the notices must be mailed is September 15, 2021.

Plan sponsors should check with their COBRA administrators to ensure this final notice is delivered in a timely manner.

For more information on these changes and other employee benefit law changes, contact a member of our Labor and Employment or Employee Benefits Group.