Plan administrators have until September 15, 2021 to distribute notices of the approaching end of the COBRA subsidy period under the American Rescue Plan Act (“Rescue Plan Act”), which by law expires after September 30, 2021.

As we previously discussed in March and April of this year, the Rescue Plan Act requires that Assistance Eligible Individuals receive a Notice of Expiration of Period of Premium Assistance between 15 and 45 days before the end of their subsidized COBRA under the Rescue Plan Act.  With the conclusion of the subsidy program on September 30^th just around the corner, this means that September 15^th is the latest possible day that a plan administrator may distribute the Expiration Notice to individuals receiving the subsidy through the end of the month.

A copy of the model notice from the U.S. Department of Labor (“DOL”), which administrators can use to fill in the applicable information and send to eligible individuals, can be found here.

If you have questions about the approaching end of the COBRA subsidy period on September 30th, or completing the model notice published by the DOL, please contact a member of Carmody’s Labor & Employment group.

This information is for educational purposes only to provide general information and a general understanding of the law. It does not constitute legal advice and does not establish any attorney-client relationship.