Date: April 28, 2021
Time: 1:00 p.m. - 2:00 p.m. ET
Contact: Diane Weber, 513.352.6501, Diane.Weber@ThompsonHine.com
The most recent COVID-19 relief bill, the American Rescue Plan Act (ARPA), was signed into law on March 11. Among other relief provided in the bill, ARPA includes a much-anticipated COBRA premium subsidy applicable to group health plan sponsors. While the DOL has issued some guidance and model notices, which were discussed on April 15 during Session One, we anticipate receiving more guidance from the IRS before Session Two. We expect that guidance to provide information about how to determine whether a termination was involuntary vs. voluntary for purposes of determining “assistance eligible individuals” and to answer a number of other open questions, including the following, about the tax credit employers are permitted to take in connection with the COBRA subsidy:
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