Over the last few months, employers and plan administrators have concentrated on identifying qualifying individuals eligible for COBRA premium assistance under the American Rescue Plan Act of 2021 (“ARP”), sending out proper notices, and collecting election forms. Now that the dust has settled on the first round of election notices, employers and plans have
A Word from the IRS on Involuntary Terminations of Employment for Purposes of the ARP COBRA Premium Subsidy
One important question that arises when determining whether an individual is eligible for the COBRA premium subsidy under the American Rescue Plan Act of 2021 (“ARP”) is whether the employee has experienced an involuntary termination of employment. (See our prior blogs on the ARP subsidy, here.) The IRS’s recent Notice 2021-31 (the “Notice”) provides
Guide to New IRS Guidance on COBRA Premium Subsidy
On May 18, 2021, the IRS released Notice 2021-31, which provides implementation guidance on the COBRA premium subsidy available under the American Rescue Plan Act of 2021 (ARP). As discussed in our prior blog posts, ARP includes a 100% COBRA premium subsidy for qualifying individuals during periods of COBRA continuation coverage from April
The Pocket Guide to COBRA Subsidy Notices
The American Rescue Plan Act of 2021 (ARP) requires that plan administrators distribute new COBRA notices to individuals in connection with the COBRA premium subsidy, as discussed in our prior blog posts. To help keep track of who gets which COBRA notice and the applicable deadline to send each notice, we have prepared a