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The ARPA and COBRA
The recently enacted American Rescue Plan Act of 2021 (ARPA) requires employers to pay 100% of the premiums required under the Consolidated Omnibus Budget Reconciliation Act (COBRA) for employees who are enrolled, or will enroll, in COBRA continuation coverage from April 1, 2021, through September 30, 2021. Employers can be reimbursed for the premium subsidy through a payroll tax credit, for which there is no income cap. In addition, the ARPA extends the COBRA election period and grants a second opportunity to elect COBRA continuation coverage for those qualified individuals who otherwise would be covered but either never elected COBRA coverage or previously discontinued their COBRA coverage. Accordingly, the ARPA requires the administrator of the applicable group health plan (or other entity) to send written notifications regarding the premium subsidy and extension, as applicable, by May 31, 2021, to those individuals who qualify. The Department of Labor (D ....

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