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To embed, copy and paste the code into your website or blog: As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”), a $1.9 trillion COVID-19 relief package, 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”). ARPA also creates a series of complicated notice requirements, each with different timelines, which employers must navigate to ensure compliance. An AEI is a former employee who has experienced a “qualifying event,” either an involuntary termination or a reduction of hours, and who is, or could have been, eligible for COBRA coverage during the Subsidy Period. The qualifying event may occur during the Subsidy Period; however, former employees who experienced earlier qualifying events are a

United statesRevenue serviceUs department of laborEpstein beckerPresident bidenAmerican rescue plan actSubsidy periodInternal revenue serviceModel noticesExtended election noticesQualifying events before aprilExtended election noticeCoverage noticeExtended election periodsQualifying events occurringThrough september