ARPA is Ending: What Does It Mean?


The end of the COBRA subsidy period is here. For a quick reminder, American Rescue Plan Act (ARPA) permitted up to six months of premiums for COBRA health coverages to be subsidized. September 30, 2021, marks the end of the subsidy period, but where does that leave COBRA participants?

Can individuals continue coverage after the end of the COBRA subsidy?

If an individual is still within their COBRA coverage period (typically 18 months from a qualifying event), they may continue with COBRA coverage. However, individuals are responsible for the full cost of premiums, plus 2%.

How does an individual continue their coverage after the subsidy?

Within 30 days prior to the end of the COBRA subsidy period, an active COBRA participant received a communication by mail that outlines their right to continue COBRA, the cost of that coverage, and how to pay for that coverage. The individual would be responsible for paying premiums by the due date or risk termination of coverage.

Does an individual need to make an election to maintain coverage after the end of the COBRA subsidy period?

No. There is no requirement to make an election to maintain coverage at the end of the subsidy period. However, individuals must pay premiums timely in order to maintain coverage. Additionally, for individuals with a calendar year plan, COBRA Open Enrollment is likely just around the corner. Watch for communications regarding your COBRA Open Enrollment Period.

Can an individual change their existing coverage as a result of the of the subsidy ending?

No. The end of the COBRA subsidy is not a qualifying event and generally would not permit an individual to select a different plan through the group.

Can I enroll in the Individual Marketplace?

Individuals (whose subsidy is ending) are eligible for a special enrollment period through the Individual Insurance Marketplace.

Will there be another COBRA subsidy?

At this time there is not another COBRA subsidy and there is not a strong indication that Congress is likely to pass another one. However, with the Pandemic Period continuing to be ongoing and COVID-19 cases on the rise nationwide, we can’t entirely rule it out.

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