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Extent of Pandemic Extensions of COBRA Deadlines Is Unclear
Proskauer 
[Guidance Overview] Feb. 15, 2021 "[The] rule is clear that disregarding relevant time periods is limited to one year. However, what is not clear is whether the tolling relief expires at the end of this month (i.e., one year from the March 1, 2020 start of the outbreak period), with all tolled periods re-starting for affected individuals, or whether the one year limit is merely a cap to be applied on an individual-by-individual basis." |
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