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ARPA's COBRA Subsidies: Similar to ARRA, But Some Important Differences
Eversheds Sutherland Link to more items from this source
[Guidance Overview]
Mar. 16, 2021

"[Q]ualified beneficiaries who are eligible for COBRA for other reasons, such as death of a covered employee, would not be eligible for a subsidy. Employers will probably need to maintain supporting documentation regarding the qualified beneficiary's COBRA election and a declaration of the covered employee's involuntary termination or reduction in hours."

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