IRS COBRA Subsidy Guidance: 11 Takeaways

On May 18, 2021, the Internal Revenue Service (“IRS”) published Notice 2021-31 (“Notice”), containing much-anticipated guidance on the American Rescue Plan Act’s (“ARPA”) COBRA premium assistance program. The Notice seeks to clarify certain matters related to the COBRA premium tax credit and explain which requirements apply to employers or plan sponsors, group health plans and/or health insurance issuers....
By: Mitchell, Williams, Selig, Gates & Woodyard,

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