To embed, copy and paste the code into your website or blog: As we previously reported, President Biden signed the American Rescue Plan Act (“ARPA”), a $1.9 trillion COVID-19 relief package, into law on March 11, 2021, which, among other things, mandates that employers provide 100 percent COBRA premium subsidies to eligible employees (“Assistance Eligible Individuals” or “AEIs”) and their qualified beneficiaries from April 1, 2021, through September 30, 2021 (“Subsidy Period”). ARPA also creates a series of complicated notice requirements, each with different timelines, which employers must navigate to ensure compliance. An AEI is a former employee who has experienced a “qualifying event,” either an involuntary termination or a reduction of hours, and who is, or could have been, eligible for COBRA coverage during the Subsidy Period. The qualifying event may occur during the Subsidy Period; however, former employees who experienced earlier qualifying events are also eligible under ARPA for an extended COBRA election period. All AEIs must be given proper notice under ARPA, although the rules vary based on the time of the qualifying event. On May 18, 2021, the Internal Revenue Service (“IRS”) issued Notice 2021-31, which answers many of the questions related to how to calculate and claim the payroll tax credit as well as other implementation items. The guidance consists of 86 Q&As on the ARPA COBRA premium assistance provisions and covers topics such as who is eligible for the premium subsidy, when a termination of employment is considered involuntary for subsidy purposes, the types of coverage to which the subsidy applies, the period to which the subsidy applies, the right to make a special COBRA election, and the interaction with state mini-COBRA coverage.