ARPA imposed three notice requirements on employers, which HMAA can send on your behalf if your company does not self-administer COBRA:
- Special Election Opportunity: No later than May 31, 2021, employers must provide notice to AEIs who are eligible for the special election opportunity.
- New Qualifying Beneficiaries: Employers must notify AEIs who become eligible to elect COBRA during the subsidy period of the subsidy’s availability.
- Notice of Subsidy Termination: Employers must generally provide a termination notice to AEIs 15 to 45 days prior to the expiration of the AEI’s COBRA subsidy. This does not apply if the AEI is losing the subsidy due to becoming eligible for another group health plan or Medicare.