American Rescue Plan Act: New Guidance on COBRA Premium Assistance

The American Rescue Plan Act (“ARPA”) became law in March of this year. One of the many relief provisions included in ARPA is a temporary subsidy of COBRA continuation premiums for certain individuals, summarized in our prior alert. On April 7, the Department of Labor’s Employee Benefits Security Administration (the “EBSA”) released model notices and FAQs (the “FAQs”) clarifying certain aspects of the changes ARPA made with respect to COBRA continuation. While interpretive questions remain, prompt action by employers and other providers of health plan benefits is necessary.

Please see full Alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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