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American Rescue Plan (ARP) includes a 100% COBRA Subsidy
Provides subsidy for certain qualified beneficiaries (QBs)
Subsidy is available Apr. 1 – Sept. 30, 2021
Subsidy covers all group health plan coverage, but not health FSAs
For federal COBRA, employer must pay carrier or cover on a self-insured plan, but may recover the premiums via a payroll tax credit
Significant new notice requirements
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