Believe it or not, it’s almost time for COBRA subsidies provided under the American Rescue Plan Act (ARPA) to end.  For the vast majority of assistance eligible individuals (AEIs) still on subsidized COBRA, the subsidy ends September 30, 2021.  Employers must provide a subsidy expiration notice between 15 and 45 days ahead of the expiration date, which means employers should be prepared to send these notices to most remaining AEIs between August 16 and September 15.

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information.

This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.