All Good Subsidies Must Come to an End: ARP’s Expiration Notice Requirements
By EsqSocial Corporation 21/04/21
As mentioned in our earlier posts, the American Rescue Plan Act of 2021 (“ARP”) provides a 100% COBRA premium subsidy for continuation coverage between April 1 and September 30, 2021 for certain assistance eligible individuals (“AEIs”). As employers and plan administrators prepare to educate AEIs about this subsidy, they cannot overlook another necessary notice: a notice to some AEIs that their subsidy is about to expire. Under a literal reading of the rules, this expiration notice might...
By: Proskauer - Employee Benefits & Executive