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ARTICLE · 28 APRIL 2021

DOL Issues Additional Guidance On Temporary COBRA Subsidy Under American Rescue Plan Act

Buchanan Ingersoll & Rooney
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As discussed in our prior advisory, the American Rescue Plan Act of 2021 (ARP) provides assistance eligible individuals temporary premium assistance for COBRA continuation coverage and, where the...

United StatesEmployment and HR
John E. McGrady
John E. McGrady
Barbara L. Sanchez-Salazar
Barbara L. Sanchez-Salazar
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As discussed in our prior advisory, the American Rescue Plan Act of 2021 (ARP) provides assistance eligible individuals temporary premium assistance for COBRA continuation coverage and, where the employer elects to offer the option, an opportunity to switch to a different health plan option offered by the employer. The Department of Labor (DOL) recently issued Model COBRA Notices and frequently asked questions (FAQs) to assist employers and group health plans in implementing the new ARP COBRA subsidy, which extends from April 1, 2021 through September 30, 2021.         

What are the new ARP COBRA notice requirements?

The ARP imposes three key notice requirements on group health plans, including:

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