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As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”) into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible employees (“Assistance Eligible Individuals” or “AEIs”) and their qualified beneficiaries from April 1, 2021, through September 30, 2021 (“Subsidy Period”). An AEI is an employee who has experienced a “qualifying event,” which is either an “involuntary termination” or a “reduction of hours,” and who is, or could have been, eligible for COBRA coverage during the Subsidy Period. Generally, the qualifying event must occur during the Subsidy Period; however, former employees who experienced qualifying events before the Subsidy Period are also eligible under ARPA for an extended COBRA election period.