The American Rescue Plan Act (ARPA), signed into law by President Biden back in March, required that “assistance-eligible individuals” (AEIs) be provided a 100% subsidy of their COBRA premiums through September 30, 2021. A separate provision of the ARPA requires that plan administrators give advance notice to AEIs when their COBRA subsidy period is coming to an end. The ARPA further mandates that the notice must be sent to AEIs no more than 45 days, nor less than 15 days before the actual expiration date of the subsidy. With the final day of the subsidy period (September 30) just over 30 days away, the expiration notices must be sent by September 15, 2021. The Department of Labor (DOL) has prepared a model expiration notice which you can access here. Should you choose to develop your own expiration notice, the ARPA requires that it be written in clear and understandable language advising that: (1) the ARPA COBRA subsidy for such individual will expire soon and the prominent identification of the date of such expiration and (2) such individual may be eligible for coverage without any subsidy through COBRA continuation coverage or coverage under a group health plan. Remember, the last day on which these expiration notices should be sent is September 15, 2021.