Yes, COBRA participants who have not paid April 2021 or May 2021 premiums should make a payment, even if they believe they will be eligible for the subsidy, to ensure there is no disruption in carrier coverage. Participants are encouraged to continue paying their monthly premiums by the indicated deadlines in the letters they have received to date.
Once the subsidy is applied to the participant’s account, payments already made will be credited forward to future months of COBRA coverage. If the participant’s COBRA ends on or before September 30, 2021, credits can be refunded back to the participant for any months the subsidy has been applied or for months they do not need additional coverage beyond the subsidy period.
Participants will receive an attestation form in their communication to be mailed by May 31, 2021. They will need to complete this form prior to the subsidy being applied to their account as the attestation form reviews the participant’s obligations in order to receive the subsidy.