To embed, copy and paste the code into your website or blog: The Internal Revenue Service issued Notice 2021-31, providing the much-anticipated guidance plan sponsors, multiemployer plans, and COBRA administrators have been waiting for related to the COBRA subsidy provisions under the American Rescue Plan Act. Notice 2021-31 (the Notice) is lengthy, at more than 40 pages with 86 questions and answers. Despite its length, much of the guidance is not surprising and is a carryover of previous Internal Revenue Service (IRS) guidance related to the COBRA subsidy under the American Recovery and Reinvestment Act of 2009. The Notice comes as plan sponsors and COBRA administrators are gearing up to issue required notices to subsidy eligible individuals under the American Rescue Plan Act (ARPA) (known as assistance eligible individuals).