As a follow-up to the guidance issued in mid-March on the American Rescue Plan (ARP), last week the Department of Labor issued the much-awaited required COBRA Model Notices. To learn more about the ARP, please visit The American Rescue Plan Act – Part 1 (COBRA Premium Assistance), The American Rescue Plan Act – Part 2 (Dependent Care Flexible Spending Accounts and Exchange Health Insurance), and What You Need to Know About the American Rescue Plan.
We have additional guidance about the COBRA Model Notices available on our Customer Resource Center including a complete advisor, DOL Issues FAQs about COBRA Premium Assistance under ARPA, and a brief, which explains what you need to know at a glance, The DOL Issues ARPA COBRA Subsidy Forms.
A few important notes for employers:
- If you are currently using a COBRA administrator: Confirm that the administrator will be providing the required notices in a timely manner and work with the administrator to determine the Assistance Eligible individuals who may be entitled to the special enrollment period.
- If your group does not use a COBRA administrator: You will need to determine the eligible individuals and prepare and distribute the required notices.
Below please find the links and a few notes about the Model Notices:
- General Notice and Election Notice: For use by group health plans for qualified beneficiaries who have qualifying events occurring from April 1, 2021 through September 30, 2021.
- Notice in Connection with Extended Election Period: For use by group health plans for qualified beneficiaries currently enrolled in COBRA continuation coverage, due to a reduction in hours or involuntary termination (Assistance Eligible Individuals), as well as those who would currently be Assistance Eligible Individuals if they had elected and/or maintained COBRA continuation coverage.
- Alternative Notice: For use by insured coverage subject to state continuation requirements between April 1, 2021 and September 30, 2021.
- Notice of Expiration of Premium Assistance: For use by group health plans to Assistance Eligible Individuals 15-45 days before their premium assistance expires.
- Summary of COBRA Premium Assistance Provisions under American Rescue Plan Act of 2021: An overview of the ARP Premium Assistance.
- FAQ’s: – Frequently Asked Questions about COBRA Premium Assistance provided by the DOL.
We expect additional guidance regarding these COBRA Model Notices in the coming weeks and will share once available. In the meantime, feel free to reach out directly to anyone from our team if you have any questions.