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IRS Guidance on ARPA COBRA Subsidies: 86 Q&As and Counting | Epstein Becker & Green


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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. ....

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May 31, 2021 Deadline Approaching for ARPA's COBRA Subsidy Election Notices | Epstein Becker & Green


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 eve ....

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