"Many employers may not be staffed to process payments other than through payroll deduction, and it may be especially difficult to set up a procedure for doing so when the staff that might handle the payments is either not working or working remotely. Moreover, if the employer is collecting premium payments from a furloughed employee who is not receiving compensation, and the individual does not make a payment, he or she may be considered to have a COBRA qualifying event at that point, and the tolling period provided by the DOL/IRS Notice would apply."

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