Subsidy Period
ARP COBRA Subsidy
Subsidy Period
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COBRA Subsidy Period is Apr. – Sept. 2021
COBRA subsidy ends the earliest of:
Federal COBRA or state continuation maximum coverage period (from the original qualifying event date) expires
Individual becomes eligible for group health plan coverage or Medicare
Sept. 30, 2021
QBs are required to notify employer of eligibility for group health plan coverage or Medicare
- Fine of $250 for failure to notify
- Increased to repayment of the premium if failure to notify was intentional
- Penalty may be forgiven for reasonable cause
Interaction with the Outbreak Period
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- Individuals who triggered a COBRA continuation right prior to Apr. 2021 might be able to take advantage of Outbreak Period extension and COBRA subsidy.
- Individuals who elect the COBRA subsidy Apr. – Sept. 2021 cannot be required to elect or pay for COBRA retroactively (but could choose to do so if still in their extended window)
Involuntary Termination of Employment
Original COBRA Election Deadline
Extended COBRA Election Deadline
Maxiumum Coverage Period Ends
Feb. 3, 2020
Mar. 1, 2020
Apr. 30, 2020
Apr. 1, 2021
Apr. 30, 2021
Aug. 31, 2021
Original COBRA Date
(Coverage available only if retroactive premiums paid)
COBRA Subsidy Available
COBRA Subsidy Ends