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Some Family Members May Not Be Eligible for the ARPA COBRA Premium Subsidy
Proskauer Link to more items from this source
[Guidance Overview]
Mar. 24, 2021

"If a former employee who is an assistance-eligible individual elects COBRA coverage that includes a family member who is not a qualified beneficiary (e.g., a domestic partner or a new spouse to whom the employee was not married at the time of the qualifying event), how much of the premium is not subsidized? And how much is the payroll tax credit to which the employer (or multiemployer plan or insurer) is entitled?"

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