As summer comes to an end, so does the COBRA Subsidy period created earlier this year by the American Rescue Plan Act. The subsidy period, which began April 1, expires September 30, 2021.
Employers are required to send an Expiration Notice to those still receiving the subsidy to let participants know about this. The notice must be sent within a period that starts 45 days before and ends 15 days after the COBRA Subsidy expiration date. Said more simply, the notices must go to subsidy participants between August 15 and September 15, 2021.
Employers who use an outside COBRA administrator will want to be sure the administrator will be sending the notices for you. Organizations that self-administer COBRA should send the model notice by September 15 to individuals still receiving the subsidy.
The notice tells the individual what their options are once the subsidy ceases. Options are to:
- Continue COBRA by self-paying the premium after September 30, 2021.
- Enroll in coverage through the Health Insurance Marketplace®. The Marketplaces will allow a special enrollment for individuals whose COBRA subsidy expires.
- Enroll in individual market health insurance coverage outside of the Marketplace.
Some participants may be eligible for Medicaid.