What Is An Involuntary Termination Or Reduction In Hours For ARPA COBRA Premium Assistance?
By EsqSocial Corporation 20/05/21
One of the first questions that must be addressed in order to determine whether an individual is eligible for the temporary 100% subsidy for COBRA health care continuation coverage (including under state mini-COBRA statutes) enacted under the American Rescue Plan Act of 2021 (“ARPA”) is whether the individual has had an involuntary termination from employment or a reduction in hours. On May 18, 2021, the IRS released Notice 2021-31, which provides guidance on this threshold question. This...
By: Brownstein Hyatt Farber Schreck