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The recently enacted American Rescue Plan Act ( ARP )
contains an important provision affecting all private employers
with 20 or more employees (and all Michigan governmental employers)
that sponsor employee health insurance plans. Below we
very briefly summarize essential aspects of the new law and
its most immediate impact on the obligations of employers and COBRA
administrators.
Under COBRA - the Consolidated Omnibus Budget Reconciliation Act
of 1985, for those too young to remember that COBRA is
not some weird reptilian reference to a health benefit - most