Group health plan sponsors that are providing the temporary COBRA premium subsidy required by the American Rescue Plan Act (ARPA) must provide advance notice to certain recipients that the COBRA subsidy will end. The notice must be provided at least 15 days, and not more than 45 days, before the earlier of Sept. 30, 2021 or the date on which the recipient will reach the end of his or her maximum COBRA coverage period. No notice is required in the case of a recipient whose COBRA coverage and subsidy are ending due to Medicare eligibility or eligibility under another group health plan.

The U.S. Department of Labor (DOL) previously published a model notice for this purpose. The six-page model notice can be accessed here. 

For those subsidy recipients whose maximum COBRA coverage period will end after Sept. 30, 2021, the notice must be provided by Sept. 15, 2021. An earlier notice deadline will apply in the case of recipients whose maximum COBRA continuation coverage period will end before Sept. 30, 2021. 

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