On July 26, 2021, the U.S. Internal Revenue Service ("IRS") issued Notice 2021-46, providing additional guidance on the Consolidated Omnibus Budget Reconciliation Act of 1985 ("COBRA").
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The Internal Revenue Service (IRS) recently published IRS Notice 2021-31, which provides additional guidance on the COBRA premium subsidy established under the American Rescue Plan Act.
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Under the American Rescue Plan Act of 2021 ( ARPA ), a 100% COBRA subsidy is available to qualified beneficiaries who lose coverage due to an involuntary termination of employment or reduction in hours. The subsidy is available for the period of April 1, 2021 through September 30, 2021, if the individual is not eligible for other group health plan coverage or Medicare. For more information, please refer to our prior Client Alerts on the new COBRA subsidy which may be accessed here and here.
On May 18, 2021, the IRS issued Notice 2021-31, which provides helpful guidance on a number of issues in the form of 86 FAQs. Part I of our series of Client Alerts on the new COBRA subsidy (which may be accessed here) addressed the following issues:
On May 18, 2021, the Internal Revenue Service (IRS) released much-anticipated guidance on premium subsidies for continuation coverage under Consolidated Omnibus Budget Reconciliation.