Employee Benefits Compliance, Subsidies

COBRA ARPA Subsidy Period Ending Soon Calling for Expiration Notices to be Sent to Subsidy Recipients

The American Rescue Plan Act (ARPA) provided for a 100% COBRA subsidy to employees and former employees who suffered an involuntary termination or any reduction in hours between April 1st and September 30th, the subsidy period, or, they may receive another “bite at the apple” if suffering this COBRA event within the preceding 18 months. For full details on the subsidy, see the prior Leavitt Group article.

As the subsidy period ends on September 30th, plan sponsors are reminded that notice of subsidy expiration will be due. Plan must send notice of expiration of the subsidy 15 to 45 days prior to the Assistance Eligible Individual (AEI) subsidy ending. A model Notice of Expiration of Premium Assistance was made available by the Department of Labor. See the prior Leavitt Group article.


Plan sponsors with AEIs having premium assistance subsidy expiring September 30th must send the Notice of Expiration by September 15.  The DOL model notice may also be found here, along with other helpful information on the COBRA ARPA subsidy. Still have questions? Contact your Leavitt Group representative for assistance. Let us be your Trusted Advisor for compliance!