Notice Requirements

Notice Requirements

ARP COBRA Subsidy

Notice Requirements

1. Notices

DOL Model Notices

  • Model General Notice and COBRA Continuation Coverage Election Notice
  • Model Notice in Connection with Extended Election Period
  • Summary of COBRA Premium Assistance Provisions (including certification form)
  • Model Notice of Expiration of Premium Assistance

2. Who Needs to Receive Which Notices?

Play the audio cast and follow along with the content below

New Qualified Beneficiaries

Now - Sept. 2021
Normal election notice replaced with:
  • Model General Notice and COBRA Continuation Coverage Election Notice & Summary of COBRA Premium Assistance Provisions (including certification form)

Existing Qualified Beneficiaries

  • Model Notice in Connection with Extended Election Period & Summary of COBRA Premium Assistance Provisions (including certification form)
  • Must be sent by May 31st, 2021

Individuals who elect COBRA subsidy

April – Sept. 2021
  • Model Notice of Expiration of Premium Assistance
  • Must be sent 15-45 days prior to the subsidy ending due to end of maximum coverage period or reaching Sept. 30th

3. Attestation

Play the audio cast and follow along with the content below

It is recommended to collect the certification that is part of the Summary of COBRA Premium Assistance Provisions

Ensure carrier/stop-loss carrier will provide coverage

Proof of the employer’s right to collect payroll tax credits

4. Federal COBRA vs. State Continuation

Play the audio cast and follow along with the content below

Plans Subject to Federal COBRA

Employer is responsible for sending notices, providing subsidized coverage, and requesting payroll tax credits.

Plans Subject to State Continuation

Carrier is responsible for providing subsidized coverage, and requesting payroll tax credits. The employer should coordinate notice distribution with the carrier.