On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (the “IRS Notice”) containing detailed guidance relating to premium assistance for COBRA benefits under the American Rescue Plan Act of 2021 (“ARPA”). The guidance provides much needed clarification on a number of practical questions for employers that arise in implementation of ARPA COBRA subsidies, which may be applicable the period from April 1, 2021 to September 30, 2021.