COBRA

Clarification of IRS Notice 221-31 and COBRA Subsidy Eligibility

On Tuesday May 19, IRS released Notice 2021-31.  This notice provides a series of questions and answers to address many issues that have arisen with respect to COBRA premium assistance available for COBRA continuation coverage under the American Rescue Plan Act (ARP). Generally, the questions and answers apply for purposes of all COBRA continuation coverage…
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COBRA

ARPA COBRA Subsidy – When is a Termination of Employment Involuntary?

Content reposted with permission from: The National Law Review and Paul M. Hamburger, co-chair of the Employee Benefits & Executive Compensation Group and head of the Washington, DC law office of Proskauer. The American Rescue Plan Act of 2021 (“ARPA”), includes a 100% COBRA premium subsidy for periods of coverage occurring between April 1 and…
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