The Department of Labor recently issued FAQs addressing basic questions regarding the American Rescue Plan Act’s requirement that employers and health plans subsidize COBRA between April 1, 2021 and September 30, 2021 for assistance eligible individuals.  In addition, the Department issued model notices which are required to be provided to certain former employees. The General Notice and Election Notice are to be used by employers who are subject to federal COBRA.  The Alternative Notice is to be used for employers which are not subject to federal COBRA but which are subject to a state’s mini-COBRA provisions.

Below are the relevant links.

• COBRA Premium Subsidy dedicated page, available at https://www.dol.gov/COBRA-subsidy
• FAQs – https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/cobra-premium-assistance-under-arp.pdf
• Model Notices:
  • General Notice and Election Notice, available at https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/cobra/premium-subsidy/model-general-and-election-notice.pdf
  • Notice in Connection with Extended Election Period, available at https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/cobra/premium-subsidy/model-extended-election-periods-notice.pdf
  • Alternative Notice, available at https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/cobra/premium-subsidy/model-alternative-election-notice.pdf
  • Notice of Expiration of Premium Assistance, available at https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/cobra/premium-subsidy/notice-of-premium-assistance-expiration-premium.pdf
  • Summary of the COBRA Premium Assistance Provisions, available at https://www.dol.gov/sites/dolgov/files/ebsa/laws-and-regulations/laws/cobra/premium-subsidy/summary-of-provisions.pdf