When President Joe Biden signed the American Rescue Plan Act of 2021 (ARPA), one of the effects was to make COBRA continuation coverage free for certain qualifying individuals and their families from April 1 to September 30, 2021. The free coverage is available to those who lose group health plan coverage because either (1) they were terminated (not including resignations) or (2) their hours were reduced. So, all you have to do is remember the two reasons and the new coverage until September 30, right? No, it’s not that easy.
The free coverage is also available to “expired COBRA participants,” i.e., those who (1) already lost coverage because of one of the two reasons and (2) could have had COBRA coverage during the period from April 1 to September 30, 2021. They would include people who either:
