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The American Rescue Plan Act (“ARPA”) made a full subsidy for six months of premiums available to COBRA-eligible individuals whose employment was involuntarily terminated or who lost coverage due to a reduction in hours. Between this subsidy program and the further extension of the COBRA notice, election, and premium payment deadlines under Department of Labor (“DOL”) and IRS guidance issued in February, health plan sponsors and administrators are contending with a number of COBRA compliance…