As part of the American Rescue Plan Act of 2021 ("ARPA"), signed into law on March 11, 2021, employers will be required to provide, on a tax-free basis, a subsidy to employees and their qualified beneficiaries to pay 100% of the COBRA continuation premium for group health plan coverage. This subsidy applies only to “assistance eligible individuals,” who are eligible for COBRA as a result of an involuntary termination of employment or a reduction in hours and who are, or could have been, eligible for COBRA during the period of April 1, 2021 through September 30, 2021 (the "Subsidy ...
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