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President Joe Biden signed the American Rescue Plan Act of 2021
(American Rescue Plan) into law on March 11, 2021. The American
Rescue Plan provides up to six months of full Consolidated Omnibus
Budget Reconciliation Act of 1985 (COBRA) premium payments for
"assistance eligible individuals" (AEIs). The COBRA
subsidy period lasts from April 1, 2021, to Sept. 30, 2021.
The American Rescue Plan provides new special election
opportunities for certain AEIs and imposes several new notice
requirements on employers with respect to the subsidies. The
quickly-approaching deadlines create some urgency for employers to